The allegations read: Finra rule 2010, nasd rule 2110 - robert gesdorf simultaneously acted as the account representative and was named as a trustee and/or beneficiary on the accounts of numerous elderly customers contrary to a member firm's policy prohibiting registered representatives from acting as the personal trustee for a client's trust, acting as an administrator for a client's trust or estate, or acting as an executor for a client's estate without prior approval from the firm's compliance department. Gesdorf claimed he was unaware of the clients' appointments of him or family members as a successor trustee, co-trustee, or beneficiaries. Gesdorf failed to disclose on a firm annual compliance questionnaire that he had been named as the successor trustee for trusts but only disclosed he was designated the executor for the clients' estates and failed to disclose he was successor trustee for other estates. Gesdorf failed to update his questionnaire after the clients' deaths and his acceptance of the trusts in writing. Gesdorf completed annual compliance questionnaires for another member firm and failed to disclose he had been designated as co-trustee/beneficiary or successor trustee for clients' trusts. Displaying a pattern of material omissions as to his fiduciary and/or beneficiary status, gesdorf failed to make 13 separate disclosures. Both of gesdorf's firms required disclosure of client gifts in excess of $100 but for seven years, he failed to disclose at least $30,300 in gifts received from clients. Gesdorf failed to disclose he held fiduciary positions or had a financial interest in trust accounts for which he served as the account representative. His dual role created a conflict of interest. His failure to disclose the relationships prevented his member firms from addressing the conflict of interests and from preventing any exploitations of his relationships with customers. As a result, gesdorf inherited $1,700,000 from one client, stands to inherit approximately $2,000,000 from a second client and is named as the beneficiary of an estate valued at over $1,000,000 for a third client. He has received cash gifts from clients totaling approximately $30,300.
