Raymond Daniel Schmidt (CRD #3258497, Oceanside, California) submitted an AWC in which he was barred from association with any FINRA member in any capacity. Without admitting or denying the findings, Schmidt consented to the sanction and to the entry of findings that he borrowed a total of $2,254,818.57 from his member firm’s customers for the purpose of purchasing real estate and constructing a vacation rental property in Hawaii, when his firm’s written procedures prohibited registered representatives from borrowing money from customers subject to certain exceptions not applicable here. At the time each loan was extended, the lender was Schmidt’s customer. The findings stated that Schmidt failed to notify the firm of his outside business activity, when he purchased the real estate investment, which he developed into a vacation rental property that opened for business. Schmidt was the sole owner and operator of the property and the business. The findings also stated that Schmidt submitted several compliance questionnaires to the firm in which he falsely denied borrowing funds from any firm customer, and failed to disclose the real estate investment or vacation rental property in response to questions asking whether he was engaged in any outside business activities. Schmidt submitted to the firm disclosures of loans, related to his purchase of the real estate investment and construction of the vacation rental property, in which he falsely stated that the reason for the loans was for construction of his personal residence. Schmidt also submitted to the firm a disclosure of outside business activities related to the vacation rental property in which he falsely represented, among other things, that he did not own any interest in the vacation rental property. The findings also included that Schmidt failed to provide FINRA-requested documents and information, and stated that he would not cooperate with FINRA’s investigation. (FINRA Case #2014042741201). Mr. Schmidt was associated with LPL Financial, LLC between July 2006 and September 2014. On March 24, 2014, FINRA announced that they had fined LPL Financial LLC $950,000 for supervisory failures related to sales of various alternative investments including non-traded real estate investment trusts (REITs), oil and gas partnerships, business development companies (BDCs), hedge funds, managed futures and other illiquid pass-through investments.