The allegations read: Without admitting or denying the findings, geake consented to the sanction and to the entry of findings that he participated in a private securities transaction by soliciting elderly investors, a husband and wife, to pledge approximately $15 million of securities as collateral to guarantee a $2.5 million loan from a bank on behalf of a startup company without providing written notice to his member firm. The findings stated that geake personally invested $100,000 in the company and was also a member of its board of directors. Geake assured the couple that their risk of investment loss was minimal. Geake structured the transaction and facilitated the paperwork on behalf of the couple. The pledge of securities as collateral for the loan was an offer of a security and the couple received shares of the company's common stock in exchange for their guarantee of the loan. By soliciting this pledge of securities and facilitating the transaction, geake participated in a private securities transaction. Subsequently, the company fully defaulted on the bank loan and closed its business and the bank called for the loan to be paid in full. As a result, the couple were required to repay the entire $2.5 million bank loan with interest. Although neither of the investors were firm customers, the firm's policies prohibited its registered representatives, including geake, from engaging in any private securities transaction without prior express written permission. The findings also stated that geake incorrectly attested to the firm on multiple annual compliance questionnaires that he had not participated in any private securities transactions.
