Raymond Joseph Lucia - FINRA BrokerCheck Report

BrokerCheck Report
RAYMOND JOSEPH LUCIA
Report #23844-66066, data current as of Thursday, February 06, 2014.
Section Title
Report Summary
Broker Qualifications
Registration and Employment History
Disclosure Events
CRD# 1073284
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2 - 3
4 - 5
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Page(s)

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RAYMOND J. LUCIA
CRD# 1073284
This broker is not currently registered with FINRA.
Report Summary for this Broker
This report summary provides an overview of the broker's professional background and conduct. Additional
information can be found in the detailed report.
Disclosure Events
All individuals registered to sell securities or provide
investment advice are required to disclose customer
complaints and arbitrations, regulatory actions,
employment terminations, bankruptcy filings, and
criminal or civil judicial proceedings.
Are there events disclosed about this broker? Yes
The following types of disclosures have been
reported:
Type Count
Regulatory Event 1
Customer Dispute 12
Termination 1
Investment Adviser Representative
Information
http://www.adviserinfo.sec.gov
The information below represents the individual's
record as a broker. For details on this individual's
record as an investment adviser representative,
visit the SEC's Investment Adviser Public
Disclosure website at
This broker is not currently registered with
FINRA.
This broker has passed:
1 Principal/Supervisory Exam
1 General Industry/Product Exam
1 State Securities Law Exam
Registration History
This broker was previously registered with the
following FINRA firm(s):
LUCIA FINANCIAL LLC
CRD# 37179
SAN DIEGO, CA
10/2006 - 06/2010
FIRST ALLIED SECURITIES, INC.
CRD# 32444
SAN DIEGO, CA
11/2007 - 06/2010
SECURITIES AMERICA, INC.
CRD# 10205
SAN DIEGO, CA
09/2002 - 11/2007
www.finra.org/brokercheck User Guidance
1
©2014 FINRA. All rights reserved. Report# 23844-66066 about RAYMOND J. LUCIA. Data current as of Thursday, February 06, 2014.

Registrations
This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently
registered and licensed with, the category of each license, and the date on which it became effective. This section also
provides, for every brokerage firm with which the broker is currently employed, the address of each branch where the
broker works.
This broker is not currently registered with FINRA.
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Industry Exams this Broker has Passed
This individual has passed 1 principal/supervisory exam, 1 general industry/product exam, and 1 state
securities law exam.
This section includes all securities industry exams that the broker has passed. Under limited circumstances, a broker
may attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying work
experience. Any exam waivers that the broker has received are not included below.
Exam Category Date
Principal/Supervisory Exams
General Securities Principal Examination 04/08/1997
Series 24
Exam Category Date
General Industry/Product Exams
General Securities Representative Examination 01/15/1983
Series 7
Exam Category Date
State Securities Law Exams
Uniform Securities Agent State Law Examination 05/23/2002
Series 63
Additional information about the above exams or other exams FINRA administers to brokers and other securities
professionals can be found at www.finra.org/brokerqualifications/registeredrep/.
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Registration History
Registration Dates Firm Name CRD# Branch Location
The broker previously was registered with the following FINRA firms:
10/2006 - 06/2010 LUCIA FINANCIAL LLC 37179 SAN DIEGO, CA
11/2007 - 06/2010 FIRST ALLIED SECURITIES, INC. 32444 SAN DIEGO, CA
09/2002 - 11/2007 SECURITIES AMERICA, INC. 10205 SAN DIEGO, CA
01/2006 - 02/2006 HELIX TRADING LLC 37179 SAN DIEGO, CA
04/1996 - 09/2002 THE ADVISORS GROUP, INC. 14035 BETHESDA, MD
06/1994 - 05/1996 JOHN HANCOCK MUTUAL LIFE INSURANCE
COMPANY
5181 BOSTON, MA
08/1991 - 05/1996 JOHN HANCOCK DISTRIBUTORS, INC. 468 BOSTON, MA
09/1992 - 07/1993 FIRST WALL STREET CORP. 13024 LA JOLLA, CA
01/1983 - 08/1991 PENN MUTUAL EQUITY SERVICES, INC. 4031 HORSHAM, PA
Employment History
Employment Dates Employer Name Employer Location
Below is the broker's employment history for up to the last 10 years.
Please note that the broker is required to provide this information only while registered with FINRA and the
information is not updated after the broker ceases to be registered. Therefore, an employment end date of
"Present" may not reflect the broker's current employment status.
12/2009 - Present RAYMOND J LUCIA ENTERPRISES SAN DIEGO, CA
10/1994 - Present RAYMOND J. LUCIA COMPANIES, INC SAN DIEGO, CA
08/1988 - Present RAYMOND J. LUCIA SAN DIEGO, CA
03/1997 - 12/2011 VANCE JACKSON LTD LAGUNA HILLS, CA
01/1993 - 12/2011 ROCKY HEMINGWAY HOUSE, LTD. AUSTIN, TX
01/1993 - 12/2011 ROCKY SPANISH KEYS I, LTD. AUSTIN, TX
10/1990 - 12/2011 CIMARRON VENTURES LTD / ROCKY MIDLAND LTD AUSTIN, TX
11/2007 - 06/2010 FIRST ALLIED SECURITIES, INC. SAN DIEGO, CA
12/2006 - 06/2010 LUCIA FINANCIAL, LLC SAN DIEGO, CA
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Employment History, continued
Employment Dates Employer Name Employer Location
04/2004 - 02/2008 RJL FINANCIAL NETWORK, L.L.C. OMAHA, NE
09/2002 - 11/2007 SECURITIES AMERICA, INC SAN DIEGO, CA
10/2006 - 12/2006 HELIX TRADING, LLC SAN DIEGO, CA
Other Business Activities
This section includes information, if any, as provided by the broker regarding other business activities the broker is
currently engaged in either as a proprietor, partner, officer, director, employee, trustee, agent or otherwise. This section
does not include non-investment related activity that is exclusively charitable, civic, religious or fraternal and is
recognized as tax exempt.
1)RADIO HOST; START:11/15/2007
2)LLK INSURANCE BROKERAGE SERVICES,LLC; LLC MEMBER; MARKETING; START DATE:4/1/09
3)RJL ENTERPRISES,INC; SOLE PROP; HOLDING CO OR SUB-S CORP; START:12/1/09
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Disclosure Events
What you should know about reported disclosure events:
1. All individuals registered to sell securities or provide investment advice are required to disclose customer
complaints and arbitrations, regulatory actions, employment terminations, bankruptcy filings, and criminal or civil
judicial proceedings.
2. Certain thresholds must be met before an event is reported to CRD, for example:
o A law enforcement agency must file formal charges before a broker is required to disclose a particular
criminal event.
o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules
or conduct governing the industry and that the activity resulted in damages of at least $5,000.
3. Disclosure events in BrokerCheck reports come from different sources:
o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers,
brokerage firms and regulators. When more than one of these sources reports information for the same
disclosure event, all versions of the event will appear in the BrokerCheck report. The different versions
will be separated by a solid line with the reporting source labeled.
4. There are different statuses and dispositions for disclosure events:
o A disclosure event may have a status of pending, on appeal, or final.
§ A "pending" event involves allegations that have not been proven or formally adjudicated.
§ An event that is "on appeal" involves allegations that have been adjudicated but are currently
being appealed.
§ A "final" event has been concluded and its resolution is not subject to change.
o A final event generally has a disposition of adjudicated, settled or otherwise resolved.
§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or
(2) an administrative panel in an action brought by a regulator that is contested by the party
charged with some alleged wrongdoing.
§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Please
note that brokers and brokerage firms may choose to settle customer disputes or regulatory
matters for business or other reasons.
§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing
on the part of the individual broker. Such matters generally involve customer disputes.
For your convenience, below is a matrix of the number and status of disclosure events involving this broker.
Further information regarding these events can be found in the subsequent pages of this report. You also may
wish to contact the broker to obtain further information regarding these events.
Final On Appeal
Pending
Regulatory Event 1 0 0
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Customer Dispute 8 4 N/A
Termination N/A 1 N/A
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Disclosure Event Details
When evaluating this information, please keep in mind that a discloure event may be pending or involve allegations
that are contested and have not been resolved or proven. The matter may, in the end, be withdrawn, dismissed,
resolved in favor of the broker, or concluded through a negotiated settlement for certain business reasons (e.g., to
maintain customer relationships or to limit the litigation costs associated with disputing the allegations) with no
admission or finding of wrongdoing.
This report provides the information exactly as it was reported to CRD and therefore some of the specific data fields
contained in the report may be blank if the information was not provided to CRD.
Regulatory - Pending
This type of disclosure event involves a pending formal proceeding initiated by a regulatory authority (e.g., a state
securities agency, self-regulatory organization, federal regulatory agency such as the Securities and Exchange
Commission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.
Disclosure 1 of 1
Reporting Source: Regulator
Regulatory Action Initiated
By:
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Sanction(s) Sought: Cease and Desist
Other: N/A
Date Initiated: 09/05/2012
Docket/Case Number: 3-15006
Employing firm when activity
occurred which led to the
regulatory action:
RAYMOND J. LUCIA COMPANIES, INC.
Product Type: No Product
Allegations: SEC ADMIN RELEASE 34-67781, IA RELEASE 3456, INVESTMENT COMPANY
ACT RELEASE 40-30193, SEPTEMBER 5, 2012: THE SECURITIES AND
EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND
IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND
CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED PURSUANT TO
SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE
ACT"), SECTIONS 203(E), 203(F) AND 203(K) OF THE INVESTMENT
ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND SECTION 9(B) OF THE
INVESTMENT COMPANY ACT OF 1940 ("INVESTMENT COMPANY ACT"),
AGAINST RAYMOND J. LUCIA, SR. ("LUCIA").
THE DIVISION OF ENFORCEMENT ALLEGED THAT: LUCIA'S FIRM WAS
REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER FROM
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THE DIVISION OF ENFORCEMENT ALLEGED THAT: LUCIA'S FIRM WAS
REGISTERED WITH THE COMMISSION AS AN INVESTMENT ADVISER FROM
SEPTEMBER 2002 THROUGH DECEMBER 2011. IN MAY 2010, THE FIRM
SOLD ITS BUSINESS AND TRANSFERRED ITS CLIENT ACCOUNTS TO
ANOTHER INVESTMENT ADVISER REGISTERED WITH THE COMMISSION.
LUCIA CURRENTLY IS A REGISTERED INVESTMENT ADVISER
REPRESENTATIVE AT THE OTHER INVESTMENT ADVISER.
ON HIS RADIO SHOW AND WEBSITE, AT SEMINARS, AND IN HIS BOOKS,
LUCIA DISCUSSES HIS PROPRIETARY WEALTH MANAGEMENT STRATEGY,
WHICH HE CALLS "BUCKETS OF MONEY" ("BOM"). A RECURRING THEME IS
THAT THE BOM STRATEGY WILL ENHANCE ONE'S ABILITY TO RETIRE IN
COMFORT AND SAFETY, PROTECT THE MONEY ONE HAS SPENT A
LIFETIME ACCUMULATING, AND GENERATE INFLATION-ADJUSTED INCOME
FOR LIFE.
TO SUPPORT THEIR CLAIMS ABOUT THE BOM STRATEGY, RESPONDENTS
CLAIMED TO HAVE EXTENSIVELY "BACKTESTED" IT. DESPITE THE CLAIMS
THEY MADE TO THE PUBLIC, THE RESPONDENTS PERFORMED SCANT, IF
ANY, BACKTESTING OF THE BOM STRATEGY.
RESPONDENTS HELD NUMEROUS SEMINARS PROMOTING THEIR BOM
STRATEGY IN AN EFFORT TO OBTAIN ADVISORY CLIENTS WHO WOULD BE
CHARGED FEES IN RETURN FOR RESPONDENTS' ADVISORY SERVICES.
RESPONDENTS PROMOTED THE BOM STRATEGY BY USING A LENGTHY
SIDESHOW AT THE SEMINAR PRESENTATIONS, AFTER PROMOTING
THOSE SEMINAR PRESENTATIONS ON LUCIA'S RADIO SHOW AND
WEBSITES.
SPREADSHEETS PURPORTEDLY VALIDATED THE SLIDESHOW'S CENTRAL
PREMISE-THAT THE BOM STRATEGY WOULD HAVE PROVIDED SUPERIOR
OUTCOMES ACROSS HISTORICAL TIME PERIODS THAN OTHER
INVESTMENT STRATEGIES, AND IS A SUPERIOR INVESTMENT STRATEGY
GOING FORWARD. IT WAS MATERIALLY MISLEADING FOR RESPONDENTS
TO CLAIM THAT THEIR ALLEGED BACKTESTING VALIDATED THE BOM
STRATEGY. AMONG OTHER REASONS, RESPONDENTS DO NOT APPEAR
TO HAVE ENGAGED IN THE "NUMEROUS" BACKTESTS AND DO NOT
APPEAR TO HAVE "PROVEN" THAT THE BOM INVESTMENT STRATEGY
WORKS.
WHILE ACKNOWLEDGING THE IMPORTANCE OF FEES, RESPONDENTS DID
NOT DISCLOSE TO INVESTORS THAT THEIR BACKTESTING, WHICH IS
PURPORTEDLY VALIDATED BY THE SPREADSHEETS, DID NOT INCLUDE
ADVISORY FEES. IN THE CALCULATIONS FOR THE SPREADSHEETS,
RESPONDENTS FAILED TO REALLOCATE ASSETS AFTER THE BOND AND
REIT BUCKETS WERE EXHAUSTED. AS A RESULT, A SUBSTANTIAL
PORTION OF THE HYPOTHETICAL PORTFOLIO WAS FULLY INVESTED IN
9

REIT BUCKETS WERE EXHAUSTED. AS A RESULT, A SUBSTANTIAL
PORTION OF THE HYPOTHETICAL PORTFOLIO WAS FULLY INVESTED IN
THE STOCK MARKET. THIS RESULTED IN OVERSTATING THE
PERFORMANCE OF THE BOM STRATEGY, AND MATERIALLY
MISREPRESENTED THE RESULTS THAT COULD BE EXPECTED FROM THE
BOM STRATEGY. AT ITS SEMINARS, THE FIRM PRESENTED
PERFORMANCE CALCULATIONS FOR SEVERAL DIFFERENT ALLOCATION
STRATEGIES WHICH PURPORT TO DEMONSTRATE THE SUPERIOR
PERFORMANCE OF THE BOM STRATEGY OVER CERTAIN TIME PERIODS.
THE ONLY DOCUMENTATION OF THOSE CALCULATIONS WHICH THE FIRM
RETAINED, HOWEVER, CONSISTS OF TWO TWO-PAGE EXCEL
SPREADSHEETS WHICH FAIL TO DUPLICATE THE ADVERTISED
INVESTMENT STRATEGY. THE CALCULATIONS FAIL TO PROVIDE FOR THE
REALLOCATION OF ASSETS THAT IS ONE OF THE HALLMARKS OF THE
BOM STRATEGY.
AS A RESULT OF THE CONDUCT, LUCIA WILLFULLY AIDED AND ABETTED
AND CAUSED THE FIRM'S VIOLATIONS OF SECTIONS 206(1), 206(2) AND
206(4) OF THE ADVISERS ACT, AND RULE 206(4)-1(A)(5) PROMULGATED
THEREUNDER; AND LUCIA WILLFULLY AIDED AND ABETTED AND CAUSED
THE FIRM'S VIOLATIONS OF SECTIONS 206(1), 206(2) AND 206(4) OF THE
ADVISERS ACT, AND RULE 206(4)-1(A)(5) PROMULGATED THEREUNDER.
Current Status: Pending
Summary: SEC INITIAL DECISION RELEASE 495, JULY 8, 2013: IT IS ORDERED THAT,
PURSUANT TO SECTION 203(E) OF THE ADVISERS ACT, THE
REGISTRATION OF LUCIA AS AN INVESTMENT ADVISER IS REVOKED.
LUCIA IS PERMANENTLY BARRED FROM ASSOCIATION WITH INVESTMENT
ADVISERS, BROKERS, OR DEALERS. LUCIA SHALL CEASE AND DESIST
FROM AIDING AND ABETTING OR CAUSING THE COMMISSION OF, ANY
VIOLATIONS OR FUTURE VIOLATIONS OF SECTIONS 206(1), 206(2), AND
206(4) OF THE ADVISERS ACT AND SHALL PAY A CIVIL MONEY PENALTY IN
THE AMOUNT OF $50,000.
PAYMENT OF PENALTIES, DISGORGEMENT, PLUS INTEREST, SHALL BE
MADE ON THE FIRST DAY FOLLOWING THE DAY THE INITIAL DECISION
BECOMES FINAL.
SEC INITIAL DECISION RELEASE 540, DECEMBER 6, 2013: THE INITIAL
DECISION ON REMAND SUPPLEMENTS THE JULY 8, 2013, INITIAL DECISION
IN THE PROCEEDING, CONFIRMS THAT THE FIRM VIOLATED SECTIONS
206(1), 206(2), AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940
(ADVISERS ACT) BY
MISREPRESENTING THE VALIDITY OF PURPORTED BACKTESTING IN
SEMINARS FOR PROSPECTIVE INVESTORS, AND THAT LUCIA AIDED AND
ABETTED THE FIRM'S VIOLATIONS OF SECTIONS 206(1), 206(2), AND 206(4)
OF THE ADVISERS ACT, AND BARS LUCIA FROM ASSOCIATING WITH AN
INVESTMENT ADVISER, BROKER, OR DEALER, REVOKES LUCIA'S
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OF THE ADVISERS ACT, AND BARS LUCIA FROM ASSOCIATING WITH AN
INVESTMENT ADVISER, BROKER, OR DEALER, REVOKES LUCIA'S
INVESTMENT ADVISER REGISTRATION, IMPOSES A CIVIL PENALTY OF
$50,000 ON LUCIA AND ORDERS LUCIA TO CEASE AND DESIST FROM
FURTHER VIOLATIONS OF THE ADVISERS ACT. THE ALJ FOUND THAT
RESPONDENTS DID NOT VIOLATE SECTIONS 204 OR RULES 204-2(A)(16)
AND 206(4)-1(A)(5) THEREUNDER.
IN THE JULY 8, 2013 INITIAL DECISION THE ADMINISTRATIVE LAW JUDGE
("ALJ") FOUND THAT LUCIA AIDED AND ABETTED THE FIRM'S VIOLATIONS
OF, SECTIONS 206(1), 206(2), AND 206(4) OF THE ADVISERS ACT BY
FRAUDULENT MISREPRESENTATIONS CONCERNING AN INVESTMENT
STRATEGY INVOLVING REAL ESTATE INVESTMENT TRUST (REIT)
SECURITIES. THE COMMISSION HAD ALLEGED THREE OTHER
MISREPRESENTATIONS IN THE ORDER INSTITUTING PROCEEDINGS
("OIP"), NAMELY, THE USE OF A MISLEADING INFLATION RATE, FAILURE TO
DEDUCT FEES OR DISCLOSE THAT THE BACKTESTS WERE NOT NET OF
FEES, AND FAILURE TO REALLOCATE ASSETS IN ACCORDANCE WITH THE
STRATEGY PRESENTED, WITHOUT DISCLOSING THAT FAILURE. THE ALJ
FOUND IN THE JULY 8, 2013 INITIAL DECISION THAT THESE ADDITIONAL
MISREPRESENTATIONS, EVEN IF TRUE, WOULD NOT HAVE RESULTED IN
DIFFERENT SANCTIONS THAN THOSE IMPOSED FOR
MISREPRESENTATIONS REGARDING REITS. ACCORDINGLY, THE ALJ
DECLINED TO ANALYZE THE THREE OTHER MISREPRESENTATIONS
ALLEGED IN THE OIP.
ON AUGUST 8, 2013, THE COMMISSION, ON ITS OWN INITIATIVE,
REMANDED THE CASE FOR FINDINGS AS TO THE THREE ADDITIONAL
ALLEGED MISREPRESENTATIONS.
THE INITIAL DECISION SHALL BECOME EFFECTIVE IN ACCORDANCE WITH
AND SUBJECT TO THE PROVISIONS OF RULE 360 OF THE COMMISSION'S
RULES OF PRACTICE, 17 C.F.R. § 201.360. THE INITIAL DECISION WILL NOT
BECOME FINAL UNTIL THE COMMISSION ENTERS AN ORDER OF FINALITY.
THE COMMISSION WILL ENTER AN ORDER OF FINALITY UNLESS A PARTY
FILES A PETITION FOR REVIEW OR MOTION TO CORRECT MANIFEST
ERROR OF FACT OR THE COMMISSION DETERMINES ON ITS OWN
INITIATIVE TO REVIEW THE INITIAL DECISION AS TO A PARTY. IF ANY OF
THESE EVENTS OCCUR, THE INITIAL DECISION SHALL NOT BECOME FINAL
AS TO THAT PARTY.
i
Reporting Source: Firm
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By:
regulatory action:
RAYMOND J LUCIA COMPANIES, INC.
Allegations: RAYMOND J LUCIA COMPANIES, INC. ("RJLC") VIOLATED SECTIONS 206(1),
206(2) AND 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-1(A)(5)
PROMULGATED THEREUNDER; LUCIA AIDED AND ABETTED AND CAUSED
RJLC'S VIOLATIONS OF SECTIONS 206(1), 206(2) AND 206(4) OF THE
ADVISERS ACT, AND RULE 206(4)-1(A)(5) PROMULGATED THEREUNDER;
LUCIA AIDED AND ABETTED AND CAUSED RJLC'S VIOLATIONS OF
SECTIONS 206(1), 206(2) AND 206(4) OF THE ADVISERS ACT, AND RULE
206(4)-1(A)(5) PROMULGATED THEREUNDER; AND RJLC VIOLATED
SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(16)
PROMULGATED THEREUNDER.
VIOLATIONS OR FUTURE VIOLATIONS OF SECTIONS
206(1), 206(2), AND 206(4) OF THE ADVISERS ACT AND SHALL PAY A CIVIL
MONEY PENALTY IN THE AMOUNT OF $50,000. PAYMENT OF PENALTIES,
DISGORGEMENT, PLUS INTEREST, SHALL BE MADE ON THE FIRST DAY
FOLLOWING THE DAY THE INITIAL DECISION BECOMES FINAL. THE INITIAL
DECISION SHALL BECOME EFFECTIVE IN ACCORDANCE WITH AND
SUBJECT TO THE PROVISIONS OF RULE 360 OF THE COMMISSION'S
RULES OF PRACTICE, 17 C.F.R. §
201.360. PURSUANT TO THAT RULE, MR. LUCIA MAY FILE A PETITION FOR
REVIEW OF THIS INITIAL DECISION WITHIN TWENTY-ONE DAYS AFTER
SERVICE OF THE INITIAL DECISION. MR. LUCIA MAY ALSO FILE A MOTION
TO CORRECT A MANIFEST ERROR OF FACT WITHIN TEN DAYS OF THE
INITIAL DECISION, PURSUANT TO RULE 111 OF THE COMMISSION'S RULES
OF PRACTICE, 17 C.F.R. § 201.111. IF A MOTION TO CORRECT A MANIFEST
ERROR OF FACT IS FILED BY MR. LUCIA, THEN HE WILL HAVE 21 DAYS TO
FILE A PETITION FOR REVIEW FROM THE DATE OF THE ORDER
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RESOLVING THE MOTION TO CORRECT MANIFEST ERROR OF FACT. THE
INITIAL DECISION WILL NOT BECOME FINAL UNTIL THE COMMISSION
ENTERS AN ORDER OF FINALITY. THE COMMISSION WILL ENTER AN
ORDER OF FINALITY UNLESS MR. LUCIA FILES A PETITION FOR REVIEW
OR MOTION TO CORRECT MANIFEST ERROR OF FACT OR THE SEC
DETERMINES ON ITS OWN INITIATIVE TO REVIEW THE DECISION.
IT SHOULD BE NOTED THAT THERE IS NO ALLEGATION OR FINDING IN THE
INITIAL DECISION THAT ANY INVESTOR ACCOUNT WAS MISHANDLED IN
ANY WAY, OR THAT ANY INVESTOR SUFFERED ANY MONETARY LOSS AS
A RESULT OF THE VIOLATIONS. PRIOR TO THE INTIAL ORDER BEING
ENTERED, THERE WERE NO CUSTOMER COMPLAINTS RELATED TO THE
POWERPOINT PRESENTATION WHICH WAS THE SUBJECT OF THE
ALLEGATIONS.
i
Reporting Source: Broker
By:
Civil and Administrative Penalty(ies)/Fine(s)
regulatory action:
RAYMOND J LUCIA COMPANIES, INC.
Allegations: SEC ADMIN RELEASE 34-67781, IA RELEASE 3456, INVESTMENT COMPANY
ACT OF 1940 RELEASE 30193,SEPTEMBER 5, 2012:
THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED
IT APPROPRIATE AND IN THE PUBLIC INTEREST
THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS
BE INSTITUTED PURSUANT TO SECTION 15(B) OF
THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), SECTIONS
203(E), 203(F) AND 203(K) OF THE INVESTMENT
ADVISERS ACT OF 1940 ("ADVISERS ACT"), AND SECTION 9(B) OF THE
INVESTMENT COMPANY ACT OF 1940 ("INVESTMENT
COMPANY ACT"), AGAINST RAYMOND J. LUCIA, SR., AND HIS FORMER
INVESTMENT ADVISER FIRM (COLLECTIVELY,
"RESPONDENTS"). THE DIVISION OF ENFORCEMENT ALLEGES THAT: THE
FIRM IS A CALIFORNIA CORPORATION LOCATED IN
13

INVESTMENT ADVISER FIRM (COLLECTIVELY,
"RESPONDENTS"). THE DIVISION OF ENFORCEMENT ALLEGES THAT: THE
FIRM IS A CALIFORNIA CORPORATION LOCATED IN
SAN DIEGO, CALIFORNIA. THE FIRM WAS REGISTERED WITH THE
COMMISSION AS AN INVESTMENT ADVISER FROM
SEPTEMBER 2002 THROUGH DECEMBER 2011. IN MAY 2010, THE FIRM
SOLD ITS BUSINESS AND TRANSFERRED ITS CLIENT
ACCOUNTS TO ANOTHER INVESTMENT ADVISER, WHICH IS REGISTERED
WITH THE COMMISSION. LUCIA CURRENTLY IS A
REGISTERED INVESTMENT ADVISER REPRESENTATIVE AT THE OTHER
INVESTMENT ADVISER. SINCE 1991, LUCIA HAS
HOSTED A DAILY RADIO SHOW WHICH WAS NATIONALLY SYNDICATED IN
2000 AND IS NOW SIMULTANEOUSLY PODCAST.
LUCIA ALSO APPEARS FREQUENTLY AS A COMMENTATOR ON A VARIETY
OF TELEVISION PROGRAMS AND IS FEATURED ON
TWO WEBSITES. IN ADDITION, LUCIA WAS THE FEATURED SPEAKER AT
REGULAR SEMINARS HOSTED BY THE FIRM ACROSS
THE COUNTRY. THESE SEMINARS WERE PROMOTED ON LUCIA'S RADIO
SHOW AND WEBSITE. IN ADDITION, LUCIA HAS
WRITTEN THREE BOOKS ON INVESTING FOR RETIREMENT: BUCKETS OF
MONEY: HOW TO RETIRE IN COMFORT AND SAFETY
(2004), READY? SET? RETIRE! (2007), AND THE BUCKETS OF MONEY
RETIREMENT SOLUTION: THE ULTIMATE GUIDE TO
INCOME FOR LIFE (2010). ON HIS RADIO SHOW AND WEBSITE, AT
SEMINARS, AND IN HIS BOOKS, LUCIA DISCUSSES HIS
PROPRIETARY WEALTH MANAGEMENT STRATEGY, WHICH HE CALLS
"BUCKETS OF MONEY" ("BOM"). LUCIA'S COMMENTS ARE
NOT LIMITED TO DISCUSSIONS OF THE BOM STRATEGY, BUT A
RECURRING THEME IS THAT THE BOM STRATEGY WILL
ENHANCE ONE'S ABILITY TO RETIRE IN COMFORT AND SAFETY, PROTECT
THE MONEY ONE HAS SPENT A LIFETIME
ACCUMULATING, AND GENERATE INFLATION-ADJUSTED INCOME FOR
LIFE. TO SUPPORT THEIR CLAIMS ABOUT THE BOM
STRATEGY, RESPONDENTS CLAIMED TO HAVE EXTENSIVELY
"BACKTESTED" IT. BACKTESTING IS GENERALLY UNDERSTOOD
AS THE PROCESS OF EVALUATING A STRATEGY, THEORY, OR MODEL BY
APPLYING IT TO HISTORICAL DATA. BACKTESTING
CALCULATES HOW A STRATEGY WOULD HAVE PERFORMED IF IT HAD
ACTUALLY BEEN APPLIED IN THE PAST. THUS, A
BACKTEST MUST UTILIZE THE ACTUAL DATA FROM THE TIME IN
QUESTION IN ORDER TO GET AN ACCURATE RESULT.
DESPITE THE CLAIMS THEY MADE TO THE PUBLIC, THE RESPONDENTS
PERFORMED SCANT, IF ANY, BACKTESTING OF THE
BOM STRATEGY. RESPONDENTS HAVE ADMITTED THAT THE ONLY
TESTING THEY PERFORMED INVOLVED: (1) SOME
CALCULATIONS LUCIA PERFORMED MANUALLY IN THE LATE 1990S,
COPIES OF WHICH NO LONGER EXIST; (2) A SO-CALLED
14

CALCULATIONS LUCIA PERFORMED MANUALLY IN THE LATE 1990S,
COPIES OF WHICH NO LONGER EXIST; (2) A SO-CALLED
"BACKTEST" FOR THE PERIOD FROM 1966 TO 2003, MEMORIALIZED ON A
TWO PAGE EXCEL SPREADSHEET, WHICH WAS
PERFORMED BY A FIRM EMPLOYEE IN 2003 (THE "1966 SPREADSHEET");
AND (3) A SO-CALLED "BACKTEST" FOR THE PERIOD
FROM 1973 TO 2003, MEMORIALIZED ON A TWO PAGE EXCEL
SPREADSHEET, WHICH WAS PERFORMED BY THE SAME FIRM
EMPLOYEE, ALSO IN 2003 (THE "1973 SPREADSHEET"). RESPONDENTS
HELD NUMEROUS SEMINARS PROMOTING THEIR BOM
STRATEGY IN AN EFFORT TO OBTAIN ADVISORY CLIENTS WHO WOULD BE
CHARGED FEES IN RETURN FOR RESPONDENTS'
ADVISORY SERVICES. RESPONDENTS PROMOTED THE BOM STRATEGY
BY USING A LENGTHY SIDESHOW AT THE SEMINAR
PRESENTATIONS, AFTER PROMOTING THOSE SEMINAR PRESENTATIONS
ON LUCIA'S RADIO
Summary: CONTINUED FROM #7) THE 1966 AND 1973 SPREADSHEETS
PURPORTEDLY VALIDATE THE SLIDESHOW'S CENTRAL PREMISE -
THAT THE BOM INVESTMENT STRATEGY WOULD HAVE PROVIDED
SUPERIOR OUTCOMES ACROSS HISTORICAL TIME PERIODS
THAN OTHER INVESTMENT STRATEGIES, AND THUS, IS A SUPERIOR
INVESTMENT STRATEGY GOING FORWARD. FOR SEVERAL
REASONS, IT WAS MATERIALLY MISLEADING FOR RESPONDENTS TO
CLAIM THAT THEIR ALLEGED BACKTESTING VALIDATED
THE BOM STRATEGY. AMONG OTHER REASONS, RESPONDENTS DO NOT
APPEAR TO HAVE ENGAGED IN THE "NUMEROUS"
BACKTESTS AND DO NOT APPEAR TO HAVE "PROVEN" THAT THE BOM
INVESTMENT STRATEGY WORKS. IN PRESENTING THE
RESULTS OF THE PURPORTED 1966 AND 1973 BACKTESTS,
RESPONDENTS DISCLOSED THAT THEY USED A HYPOTHETICAL
3% INFLATION RATE, ALTHOUGH THEY USED ACTUAL HISTORICAL DATA
FOR RETURNS ON STOCKS AND BONDS. LUCIA
ADMITTEDLY KNEW THAT USING A LOWER INFLATION RATE FOR THE
BACKTESTS WOULD MAKE THE RESULTS LOOK MORE
FAVORABLE FOR THE BOM STRATEGY. MOREOVER, ACTUAL FIGURES
FOR THE INFLATION RATE DURING THE TIME PERIOD
1966 THROUGH 2003 WERE READILY AVAILABLE FROM THE DEPARTMENT
OF LABOR WHEN RESPONDENTS PERFORMED THE
CALCULATIONS IN 2003. RESPONDENTS DID NOT MAKE ANY PROVISION IN
THE 1966 AND 1973 SPREADSHEETS FOR
ADVISORY FEES. WHILE ACKNOWLEDGING THE IMPORTANCE OF FEES,
RESPONDENTS DID NOT DISCLOSE TO INVESTORS
THAT THEIR BACKTESTING, WHICH IS PURPORTEDLY VALIDATED BY THE
1966 AND 1973 SPREADSHEETS, DID NOT INCLUDE
ADVISORY FEES. IN THE CALCULATIONS FOR THE 1966 AND 1973
15

1966 AND 1973 SPREADSHEETS, DID NOT INCLUDE
ADVISORY FEES. IN THE CALCULATIONS FOR THE 1966 AND 1973
SPREADSHEETS, RESPONDENTS FAILED TO REALLOCATE
ASSETS AFTER THE BOND AND REIT BUCKETS WERE EXHAUSTED. AS A
RESULT, A SUBSTANTIAL PORTION OF THE
HYPOTHETICAL PORTFOLIO WAS FULLY INVESTED IN THE STOCK MARKET
FROM 1981 TO 2003 (IN THE 1966 SPREADSHEET)
AND FROM 1986 TO 2003 (IN THE 1973 SPREADSHEET). THIS RESULTED IN
OVERSTATING THE PERFORMANCE OF THE BOM
STRATEGY, AND MATERIALLY MISREPRESENTED THE RESULTS THAT
COULD BE EXPECTED FROM THE BOM STRATEGY. AT ITS
SEMINARS, THE FIRM PRESENTED PERFORMANCE CALCULATIONS FOR
SEVERAL DIFFERENT ALLOCATION STRATEGIES WHICH
PURPORT TO DEMONSTRATE THE SUPERIOR PERFORMANCE OF THE
BOM STRATEGY OVER CERTAIN TIME PERIODS. THE ONLY
DOCUMENTATION OF THOSE CALCULATIONS WHICH THE FIRM RETAINED,
HOWEVER, CONSISTS OF TWO TWO-PAGE EXCEL
SPREADSHEETS WHICH FAIL TO DUPLICATE THE ADVERTISED
INVESTMENT STRATEGY. THE CALCULATIONS FAIL TO PROVIDE
FOR THE REALLOCATION OF ASSETS THAT IS ONE OF THE HALLMARKS
OF THE BOM STRATEGY. AS A RESULT OF THE
CONDUCT, THE FIRM WILLFULLY VIOLATED SECTIONS 206(1), 206(2)AND
206(4) OF THE ADVISERS ACT, AND RULE 206(4)-
1(A)(5)PROMULGATED THEREUNDER; LUCIA WILLFULLY AIDED AND
ABETTED AND CAUSED THE FIRM'S VIOLATIONS OF SECTIONS 206(1),
PROMULGATED THEREUNDER;
LUCIA WILLFULLY AIDED AND ABETTED AND CAUSED THE FIRM'S
VIOLATIONS OF SECTIONS 206(1), 206(2) AND 206(4) OF
THE ADVISERS ACT, AND RULE 206(4)-1(A)(5) PROMULGATED
THEREUNDER; AND THE FIRM WILLFULLY VIOLATED SECTION
204 OF THE ADVISERS ACT AND RULE 204-2(A)(16) PROMULGATED
HEREUNDER. IT IS ORDERED THAT THE ADMINISTRATIVE
LAW JUDGE SHALL ISSUE AN INITIAL DECISION NO LATER THAN 300 DAYS
FROM THE DATE OF SERVICE OF THIS ORDER,
PURSUANT TO RULE 360(A)(2) OF THE COMMISSION'S RULES OF
PRACTICE.
16

Customer Dispute - Settled
This type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civil
suit containing allegations of sale practice violations against the broker that resulted in a monetary settlement to the
customer.
Disclosure 1 of 2
Employing firm when
activities occurred which led
to the complaint:
Allegations:
CLIENTS ALLEGE 1) VIOLATION OF COMMON LAW FRAUD; 2) BREACH OF
FIDUCIARY DUTY; AND 3) NEGLIGENCE FROM 2006 TO PRESENT.
Product Type: Real Estate Security
Alleged Damages: $80,000.00
Date Complaint Received: 06/25/2012
Complaint Pending? No
Status:
Status Date: 11/29/2012
Settlement Amount: $14,999.00
Individual Contribution
Amount:
$0.00
Summary: I DO NOT KNOW THESE INDIVIDUALS, DID NOT MAKE ANY
RECOMMENDATIONS AS TO THEIR FINANCIAL SITUATION OR INTERACT
WITH THEM AS ALLEGED. ALTHOUGH I WAS LISTED ON THE ACCOUNT
FOR ADMINISTRATIVE PURPOSES, IN MY OPINION, CLAIMANT'S ATTORNEY
Customer Complaint Information
Settled
Is this an oral complaint? No
Is this a written complaint? No
Is this an arbitration/CFTC
reparation or civil litigation?
Yes
Arbitration/Reparation forum
or court name and location:
FINRA
Docket/Case #: 12-02221
Filing date of
arbitration/CFTC reparation
or civil litigation:
06/11/2012
17

Summary:
NAMED ME IN THIS COMPLAINT BECAUSE OF MY PUBLIC PROFILE.
i
Employing firm when
to the complaint:
Allegations:
CLIENTS ALLEGE 1) VIOLATION OF COMMON LAW FRAUD; 2) BREACH OF
FIDUCIARY DUTY; AND 3) NEGLIGENCE FROM
2006 TO PRESENT.
Complaint Pending? Yes
Settlement Amount:
Amount:
Summary: I DO NOT KNOW THESE INDIVIDUALS, DID NOT MAKE ANY
Yes
FINRA
Filing date of
06/11/2012
18

Disclosure 2 of 2
i
Employing firm when
to the complaint:
Allegations:
CLIENTS ARE ALLEGING 1.) FAILURE TO SUPERVISE; AND 2.) BREACH OF
FIDUCIARY DUTY IN CONNECTION WITH THE FAILURE TO EXECUTE
STOP-LOSS ORDERS BETWEEN JUNE AND DECEMBER 2008.
Product Type: Equity Listed (Common & Preferred Stock)
Other: EXCHANGE TRADED FUNDS
Status:
Settlement Amount: $18,000.00
Amount:
$0.00
Summary: MR. LUCIA WAS LISTED AS A JOINT REPRESENTATIVE ON THE ACCOUNT
FOR ADMINISTRATIVE PURPOSES, BUT DID NOT INTERACT WITH THE
CLIENT AND MADE NO RECOMMENDATIONS OR REPRESENTATIONS, AS
THOSE ALLEGED, OR OTHERWISE. THE MATTER WAS SETTLED FOR
Settled
Yes
FINRA
Filing date of
12/01/2009
19

CLIENT AND MADE NO RECOMMENDATIONS OR REPRESENTATIONS, AS
THOSE ALLEGED, OR OTHERWISE. THE MATTER WAS SETTLED FOR
BUSINESS CONSIDERATIONS IN ORDER TO AVOID THE COST OF
ARBITRATION. U-4 QUESTIONS UPDATED 3/1/2010.
20

Customer Dispute - Closed-No Action/Withdrawn/Dismissed/Denied
This type of disclosure event involves (1) a consumer-initiated, investment-related arbitration or civil suit containing
allegations of sales practice violations against the individual broker that was dismissed, withdrawn, or denied; or (2) a
consumer-initiated, investment-related written complaint containing allegations that the broker engaged in sales practice
violations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, or conversion of
funds or securities, which was closed without action, withdrawn, or denied.
Disclosure 1 of 2
Employing firm when
to the complaint:
Allegations:
FIRST ALLIED SECURITIES INC. AND SECURITIES AMERICA, INC.
CLAIMANTS ALLEGE THAT, BEGINNING IN NOVEMBER 2005 AND
CONTINUING TO FEBRUARY 2009, THE REPRESENTATIVE RECOMMENDED
AND SOLD THEM UNSUITABLE INVESTMENTS IN VARIABLE ANNUITIES AND
VARIOUS REITS. ADDITIONAL ALLEGATIONS INCLUDE
MISREPRESENATION AND MATERIAL OMISSIONS, BREACH OF FIDUCIARY
DUTIES, NEGLIGENCE, FRAUD,VIOLATION OF PENNSYLVANIA CONSUMER
PROTECTION LAWS AND VIOLATION OF THE PENNSYLVANIA SECURITIES
ACT.
Product Type: Annuity-Variable
Real Estate Security
Date Notice/Process Served: 10/17/2012
Arbitration Pending? No
Disposition: Settled
Disposition Date: 08/21/2013
Monetary Compensation
Amount:
$70,000.00
Arbitration Information
Alleged Damages Amount
Explanation (if amount not
exact):
DAMAGES ARE ALLEGED IN EXCESS OF $300,000.
Arbitration/CFTC reparation
claim filed with (FINRA, AAA,
CFTC, etc.):
FINRA
21

Amount:
$70,000.00
Amount:
$23,333.33
i
Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE 1) UNSUITABILITY; 2) MISREPRESENTATION; 3)
RECKLESSNESS; AND 4) VIOLATIONS OF PENNSYLVANIA SECURITIES ACT
AND UTPCPL FROM SEPTEMBER 2005 TO SEPTEMBER 2012.
Direct Investment-DPP & LP Interests
Status:
Settlement Amount:
Amount:
Evolved into Arbitration/CFTC reparation (the individual is a named party)
Is this a written complaint? Yes
No
CFTC, etc.):
FINRA
22

Arbitration Pending? No
Disposition: Settled
Amount:
$70,000.00
Litigation Pending? No
Disposition: Other: REFERRED TO FINRA ARBITRATION
Amount:
$23,333.00
Civil Litigation Information
Type of Court: State Court
Name of Court: COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY
Location of Court: PHILADELPHIA COUNTY, PA
Docket/Case #: 003472
i
Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE 1) UNSUITABILITY; 2) MISREPRESENTATION; 3)
RECKLESSNESS; AND 4) VIOLATIONS OF PENNSYLVANIA SECURITIES ACT
AND UTPCPL FROM SEPTEMBER 2005 TO SEPTEMBER 2012.
Direct Investment-DPP & LP Interests
reparation or civil litigation? 23

Status:
Settlement Amount:
Amount:
Arbitration Pending? Yes
Litigation Pending? No
Disposition: Other: REFERRED TO FINRA ARBITRATION
Summary: MR. LUCIA MADE NO RECOMMENDATIONS TO CLAIMANTS PERSONALLY
OR THROUGH AGENTS, SZTROM AND PARRILLO. FURTHER, IT APPEARS
THAT CLAIMANTS ARE ATTEMPTING TO BENEFIT FROM ALLEGATIONS
MADE BY THE SEC'S ORDER OF ADMINISTRATIVE PROCEEDING TO
RECOVER LOSSES THEY INCURRED BY LIQUIDATING INVESTMENTS AS
PER THE RECOMMENDATIONS OF A NEW INVESTMENT ADVISOR. MR.
LUCIA INTENDS TO VIGOROUSLY DEFEND THIS ALLEGATION.
Civil Litigation Information
No
CFTC, etc.):
FINRA
Type of Court: State Court
Name of Court: COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY
Location of Court: PHILADELPHIA COUNTY, PA
Docket/Case #: 003472
24

PER THE RECOMMENDATIONS OF A NEW INVESTMENT ADVISOR. MR.
LUCIA INTENDS TO VIGOROUSLY DEFEND THIS ALLEGATION.
Disclosure 2 of 2
i
Employing firm when
to the complaint:
Allegations:
THE ADVISORS GROUP, INC.
IN CONNECTION WITH A VUL POLICY, CLIENT ALLEGES THAT RR
MISREPRESENTED PRODUCT AS A PRIVATE PENSION PLAN AND INDUCED
CLIENT TO PURCHASE POLICY BY REPLACING PORTION OF EXISTING
POLICY WHICH IS IN JEOPOARDY OF LAPSING.
Product Type: Other
Other Product Type(s): VUL
Status:
Settlement Amount:
Amount:
Denied
i
Employing firm when
to the complaint:
Allegations:
THE ADVIORS GROUP, INC
IN CONNECTION WITH A VL POLICY, CLIENT ALLEGES THAT RR
MISREPRESENTED PRODUCT AS PRIVATE PENSION PLAN AND INDUCED
CLIENT TO PURCHASE POLICY BY REPLACING PORTION OF EXISTING
POLICY WHICH IS IN JEOPARDY OF LAPSING.
Product Type: Annuity(ies) - Variable
$69,636.00
25

Status:
Settlement Amount:
Amount:
Summary: ACACIA LIFE ERRONEOUSLY INFORMED CUSTOMER THAT HIS POLICY
WAS A MEC. IT IS NOT. CUSTOMER FAILED TO PAY HIS REQUIRED
ANNUAL PREMIUMS, DESPITE SEVERAL NOTICES, AND DUE TO THIS AND
THE DECLINE IN THE STOCK MARKET HIS JOHN HANCOCK POLICY IS IN
JEOPARDY. CUSTOMER MISTAKENLY BELIEVED THE OLD POLICY WOULD
PRODUCE A BETTER RESULT THAN THE NEW POLICY.
Denied
26

Customer Dispute - Pending
This type of disclosure event involves (1) a pending consumer-initiated, investment-related arbitration or civil suit that
contains allegations of sales practice violations against the broker; or (2) a pending, consumer-initiated, investment-
related written complaint containing allegations that the broker engaged in, sales practice violations resulting in
compensatory damages of at least $5,000, forgery, theft, or misappropriation, or conversion of funds or securities.
Disclosure 1 of 8
Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE 1) VIOLATION OF COMMON LAW FRAUD; 2) BREACH
OF FIDUCIARY DUTY; 3) UNSUITABILITY; AND 4) NEGLIGENCE.
Settlement Amount:
Amount:
Yes
FINRA
Filing date of
08/12/2013
Disclosure 2 of 8
i
27

Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE: 1) COMMON LAW FRAUD, BREACH OF FIDUCIARY
DUTY, AND 3) NEGLIGENCE.
Settlement Amount:
Amount:
Yes
FINRA
Filing date of
08/05/2013
Disclosure 3 of 8
i
Employing firm when
to the complaint:
Allegations:
SECURITIES AMERICA AND FIRST ALLIED SECURITIES, INC.
CLAIMANTS ALLEGE 1) UNSUITABILITY; 2) BREACH OF FIDUCIARY DUTY; 3)
NEGLIGENCE; AND 4) BREACH OF CONTRACT REGARDING CERTAIN REIT
PURCHASES
$0.00
28

Alleged Damages: $0.00
exact):
NO DAMAGE AMOUNT ALLEGED.
CFTC, etc.):
FINRA
Disclosure 4 of 8
i
Employing firm when
to the complaint:
Allegations:
FIRST ALLIED SECURITIES, INC. AND SECURITIES AMERICA, INC.
IN CONNECTION WITH THE RECOMMENDATION TO INVEST IN REITS IN
LATE 2004, CLAIMANTS ALLEGE UNSUITABILITY, BREACH OF FIDUCIARY
DUTY, NEGLIGENCE, AND BREACH OF CONTRACT.
exact):
ALLEGED DAMAGES ARE NOT SPECIFIED BUT THE FIRM HAS MADE A
GOOD FAITH DETERMINATION THAT DAMAGES FROM THE ALLEGED
CONDUCT WOULD BE GREATER THAN $5,000.
CFTC, etc.):
FINRA
29

Disclosure 5 of 8
i
Employing firm when
to the complaint:
Allegations:
CLAIMANT ALLEGES: 1) BREACH OF FIDUCIARY DUTY; 2) UNSUITABILITY;
3) NEGLIGENCE; AND 4) VIOLATION OF STATE SECURITIES LAWS FROM
JUNE 2006 THROUGH JUNE 2008.
Status:
Settlement Amount:
Amount:
exact):
CLAIMANT ALSO ASKS FOR INTEREST AT $164.49 PER DAY.
No
CFTC, etc.):
FINRA
30

Date Notice/Process Served:
Disclosure 6 of 8
i
Employing firm when
to the complaint:
Allegations:
CLAIMANT ALLEGES 1) COMMON LAW FRAUD; 2) BREACH OF FIDUCIARY
DUTY; AND 3) NEGLIGENCE.
Settlement Amount:
Amount:
Yes
FINRA
Filing date of
01/02/2013
i
Employing firm when
to the complaint:
Allegations:
31

Allegations: CLAIMANT ALLEGES 1) COMMON LAW FRAUD; 2) BREACH OF FIDUCIARY
DUTY; AND 3) NEGLIGENCE.
Settlement Amount:
Amount:
Summary: MR. LUCIA IS NOT A NAMED RESPONDENT IN THIS CASE. HE DID NOT
MEET WITH THE CLAIMANT AND MADE NO INDIVIDUAL
RECOMMENDATIONS TO PURCHASE THE INVESTMENTS OF WHICH THE
CLAIMANT NOW COMPLAINS. IT APPEARS THAT CLAIMANTS ARE
ATTEMPTING TO BENEFIT FROM ALLEGATIONS MADE BY THE SEC'S
ORDER OF ADMINISTRATIVE PROCEEDING TO RECOVER ALLEGED
LOSSES.
Yes
FINRA
Filing date of
01/02/2013
Disclosure 7 of 8
i
Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE: 1) VIOLATION OF COMMON LAW FRAUD; 2) BREACH
OF FIDUCIARY DUTY; AND 3) NEGLIGENCE.
32

Allegations:
Settlement Amount:
Amount:
Yes
FINRA
Filing date of
11/14/2012
i
Employing firm when
to the complaint:
Allegations:
CLAIMANTS ALLEGE: 1) VIOLATION OF COMMON LAW FRAUD; 2) BREACH
33

Settlement Amount:
Amount:
Summary: MR. LUCIA IS NOT A NAMED RESPONDENT IN THIS CASE. HE DID NOT
MEET WITH CLAIMANTS AND MADE NO INDIVIDUAL RECOMMENDATIONS
TO PURCHASE THE INVESTMENTS OF WHICH THEY COMPLAIN. IT
APPEARS THAT CLAIMANTS ARE ATTEMPTING TO BENEFIT FROM
ALLEGATIONS MADE BY THE SEC'S ORDER OF ADMINISTRATIVE
PROCEEDING TO RECOVER THEIR ALLEGED LOSSES.
Yes
FINRA
Filing date of
11/14/2012
Disclosure 8 of 8
i
Employing firm when
to the complaint:
Allegations:
IN MAY 2008, THE INVESTOR PURCHASED A REAL ESTATE INVESTMENT
TRUST (REIT) FOR $500,000 THROUGH THE BROKER-DEALER, FIRST
ALLIED SECURITIES, INC. OVER FOUR YEARS LATER, THE INVESTOR NOW
RAISES SUITABILITY CONCERNS NOTWITHSTANDING HIS WRITTEN
ACKNOWLEDGEMENT OF RECEIPT FOR THE PROSPECTUS AND OTHER
DISCLOSURES, AND FURTHER NOTWITHSTANDING THAT HE PROVIDED
FINANCIAL INFORMATION SUPPORTING HIS SUITABILITY FOR THE
INVESTMENT. THE INVESTOR'S CONCERNS APPEAR TO BE BASED ON
COMMUNICATIONS RECEIVED FROM THE REIT SPONSOR RELATED TO A
DECREASE IN DISTRIBUTIONS. THE INVESTOR FAILS TO MENTION THE
FACT THAT HE HAD PURCHASED ANOTHER REIT IN 2006 AND HAD PRIOR
REIT EXPERIENCE. A WRITTEN RESPONSE WAS SENT TO THE INVESTOR
BY OUTSIDE LEGAL COUNSEL DENYING THE ALLEGATIONS.
34

REIT EXPERIENCE. A WRITTEN RESPONSE WAS SENT TO THE INVESTOR
BY OUTSIDE LEGAL COUNSEL DENYING THE ALLEGATIONS.
Settlement Amount:
Amount:
Summary: MR. LUCIA MAINTAINS THAT THE TRANSACTION IN QUESTION WAS
SUITABLE. THE INVESTOR UNDERSTOOD THE RISKS RELATED TO THE
INVESTMENT IN QUESTION AND HAD PRIOR EXPERIENCE INVESTING IN
REAL ESTATE, INCLUDING REAL ESTATE INVESTMENT TRUSTS. MR. LUCIA
DENIES THE ALLEGATIONS AND INTENDS TO VIGOROUSLY DEFEND
HIMSELF.
No
35

Employment Separation After Allegations
This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permitted
to resign after being accused of (1) violating investment-related statutes, regulations, rules or industry standards of
conduct; (2) fraud or the wrongful taking of property; or (3) failure to supervise in connection with investment-related
statutes, regulations, rules, or industry standards of conduct.
Disclosure 1 of 1
Employer Name: RJL WEALTH MANAGEMENT, LLC
Termination Type: Voluntary Resignation
Termination Date: 07/12/2013
Allegations: RAYMOND J LUCIA COMPANIES, INC. ("RJLC") VIOLATED SECTIONS 206(1),
PROMULGATED THEREUNDER; LUCIA AIDED AND ABETTED AND CAUSED
RJLC'S VIOLATIONS OF SECTIONS 206(1), 206(2) AND 206(4) OF THE
ADVISERS ACT, AND RULE 206(4)-1(A)(5) PROMULGATED THEREUNDER;
LUCIA AIDED AND ABETTED AND CAUSED RJLC'S VIOLATIONS OF
SECTIONS 206(1), 206(2) AND 206(4) OF THE ADVISERS ACT, AND RULE
206(4)-1(A)(5) PROMULGATED THEREUNDER; AND RJLC VIOLATED
SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(16)
PROMULGATED THEREUNDER.
VIOLATIONS OR FUTURE VIOLATIONS OF SECTIONS
206(1), 206(2), AND 206(4) OF THE ADVISERS ACT AND SHALL PAY A CIVIL
MONEY PENALTY IN THE AMOUNT OF $50,000. PAYMENT OF PENALTIES,
DISGORGEMENT, PLUS INTEREST, SHALL BE MADE ON THE FIRST DAY
FOLLOWING THE DAY THE INITIAL DECISION BECOMES FINAL. THE INITIAL
DECISION SHALL BECOME EFFECTIVE IN ACCORDANCE WITH AND
SUBJECT TO THE PROVISIONS OF RULE 360 OF THE COMMISSION'S
RULES OF PRACTICE, 17 C.F.R. §
201.360. PURSUANT TO THAT RULE, MR. LUCIA MAY FILE A PETITION FOR
REVIEW OF THIS INITIAL DECISION WITHIN TWENTY-ONE DAYS AFTER
SERVICE OF THE INITIAL DECISION. MR. LUCIA MAY ALSO FILE A MOTION
TO CORRECT A MANIFEST ERROR OF FACT WITHIN TEN DAYS OF THE
INITIAL DECISION, PURSUANT TO RULE 111 OF THE COMMISSION'S RULES
ERROR OF FACT IS FILED BY MR. LUCIA, THEN HE WILL HAVE 21 DAYS TO 36

RESOLVING THE MOTION TO CORRECT MANIFEST ERROR OF FACT. THE
INITIAL DECISION WILL NOT BECOME FINAL UNTIL THE COMMISSION
ENTERS AN ORDER OF FINALITY. THE COMMISSION WILL ENTER AN
ORDER OF FINALITY UNLESS MR. LUCIA FILES A PETITION FOR REVIEW
OR MOTION TO CORRECT MANIFEST ERROR OF FACT OR THE SEC
DETERMINES ON ITS OWN INITIATIVE TO REVIEW THE DECISION.
IT SHOULD BE NOTED THAT THERE IS NO ALLEGATION OR FINDING IN THE
INITIAL DECISION THAT ANY INVESTOR ACCOUNT WAS MISHANDLED IN
ANY WAY, OR THAT ANY INVESTOR SUFFERED ANY MONETARY LOSS AS
A RESULT OF THE VIOLATIONS. PRIOR TO THE INTIAL ORDER BEING
ENTERED, THERE WERE NO CUSTOMER COMPLAINTS RELATED TO THE
POWERPOINT PRESENTATION WHICH WAS THE SUBJECT OF THE
ALLEGATIONS.
37

End of Report
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38

Raymond Joseph Lucia - FINRA BrokerCheck Report

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