History Of Kevin Paul Rast
Rast first became associated with a FINRA member firm in 1987. Rast became registered
with FINRA in numerous capacities, including as a General Securities Representative,
General Securities Principal, Municipal Securities Principal. Rast held the positions of
Chief Executive Officer and Executive Managing Director of CFG Capital Markets, LLC
(CFGCM) (CRD No. 39468), from 2011 to October 2019. Rast remained registered
through CFGCM as an Equity Trader Limited Representative until January 2016, and in
the remaining of the above-listed capacities until October 2019.
Rast has not been associated with a FINRA member firm since October 2019, but he
remains subject to FINRA’s jurisdiction pursuant to Article V, Section 4 of FINRA’s ByLaws.
Respondent does not have any relevant disciplinary history.
Kevin Paul Rast Report
Rast Violated MSRB Rule G-17 When He Altered Documents And Produced Them To
MSRB Rule G-17 provides that in the conduct of its municipal securities or municipal
advisory activities, each broker, dealer, municipal securities dealer, and municipal
advisor shall deal fairly with all persons and shall not engage in any deceptive, dishonest,
or unfair practice.
On May 6, 2016, and August 18, 2016, FINRA sent CFGCM requests seeking “[c]opies
of any and all documents evidencing that a supervisory review of trade reporting
compliance of municipal securities was conducted during” January 1, 2016, through
March 31, 2016, and April 1, 2016, through June 30, 2016.
On May 19, 2016, and September 8, 2016, Rast downloaded a total of 12 report cards
from the MSRB’s Real-time Transaction Reporting System (RTRS). The report cards
related to CFGCM’s municipal securities reporting from January 2016 through June 2016
and showed the number and percentage of trades the firm reported late. Each report card
included the date Rast downloaded the document from RTRS. Rast deleted the download
dates on each report card, circled percentages on some report cards, and initialed each one.
He then produced these altered documents to FINRA on May 20, 2016, and September 9,
- By producing the altered documents in response to FINRA’s requests for evidence
of supervisory review, Rast gave the false appearance of contemporaneous supervisory
review of the firm’s report cards when he had not conducted such a review,
notwithstanding that he may have conducted some supervision of trade reporting.
Rast altered the RTRS report cards that he knew would be produced to FINRA. By virtue
of the foregoing, Rast did not deal fairly with all persons and engaged in a deceptive,
dishonest, or unfair practice in violation of MSRB Rule G-17.
Rast Violated MSRB Rule G-17 When He Failed To Disclose Potential Conflicts Of
Rule G-17 establishes a “general duty of a dealer to deal fairly with all persons
(including, but not limited to, issuers of municipal securities), even in the absence of
fraud.”1 MSRB Notice 2012-25, which provides interpretive guidance on Rule G-17,
states that an underwriter of municipal securities must disclose to the issuer any
“potential or actual material conflicts of interest,” including those with third parties, and
the disclosures “must be made in writing to an official of the issuer.” Likewise, MSRB
Notice 2009-42, which also provides interpretive guidance on Rule G-17, states that the
duty to deal fairly in Rule G-17 “places several specific obligations on dealers with
respect to their dealings with customers, including the obligation to disclose material
In the fourth quarter of 2015, Rast was CFGCM’s CEO, Executive Managing Director
and Municipal Securities Principal. CFGCM served as the co-underwriter in two
municipal bond offerings. As the Municipal Securities Principal responsible for
oversight of CFGCM’s activities in connection with the offerings, Rast was responsible
for ensuring that all appropriate disclosures were made, in writing, to the offering
In both offerings, the proceeds were lent to a 501(c)(3) non-profit entity and used to
purchase and redevelop specific housing projects. Company A acted as “Asset Manager”
and “Consultant” in each of the deals. According to the Official Statements (OS), in its
role as Asset Manager, Company A performed “oversight activities” on behalf of the
borrower and the projects. As Consultant, Company A’s responsibilities included “certain
services with respect to the acquisition, financing, and development” of the projects.
Company A, as Consultant, also recommended to the issuers the use of municipal bonds
over other funding alternatives.
During the time it was acting as co-underwriter, CFGCM had the following financial
relationships with Company A and its affiliate, Affiliate A:
CFGCM had made a $175,000 equity investment in Company A. In exchange,
CFGCM received seven Class A Preferred Member Units in Company A and was
offered a seat on Company A’s board.
CFGCM had lent $75,000 to Affiliate A, which had not been repaid in full at the
time of the bond offerings.
Interpretative Notice Concerning the Application of MSRB Rule G-17 to Underwriters of Municipal Securities
(Aug. 2, 2012) (MSRB Notice 2012-25).
2 Guidance on Disclosure and Other Sales Practice Obligations to Individual and Other Retail Investors in
Municipal Securities (July 14, 2009) (MSRB Notice 2009-42).
Read more about: Alpha Investment Consulting Group
CFGCM obtained its role as co-underwriter, even though it had no previous experience
with municipal bond offerings, through the intercession of the owners of Company A and
CFGCM did not make a written disclosure of these relationships with Company A or
Affiliate A to the issuers, customers, or other participants in the bond offerings,
notwithstanding the potential conflicts of interest they posed. Neither OS disclosed the
financial relationships between CFGCM and Company A and Affiliate A, nor did they
disclose that CFGCM had been offered the opportunity to nominate a board member
for Company A.
By virtue of the foregoing, Rast violated MSRB Rule G-17.
Penalties, Punishments & Sanctions
• A four-month suspension from association with any FINRA member firm in
any and all capacities; and
• A fine in the amount of $7,500.
The fine shall be due and payable either immediately upon reassociation with a member
firm, or prior to any application or request for relief from any statutory disqualification
resulting from this or any other event or proceeding, whichever is earlier.
Respondent specifically and voluntarily waives any right to claim an inability to pay, now
or at any time hereafter, the monetary sanction imposed in this matter.
Respondent understands that if he is barred or suspended from associating with any
FINRA member, he becomes subject to a statutory disqualification as that term is defined
in Article III, Section 4 of FINRA’s By-Laws, incorporating Section 3(a)(39) of the
Securities Exchange Act of 1934. Accordingly, he may not be associated with any
FINRA member in any capacity, including clerical or ministerial functions, during the
period of the bar or suspension. See FINRA Rules 8310 and 8311
Kevin Paul Rast Review
In response to FINRA requests for evidence of supervisory reviews of municipal
securities trading, Rast altered and submitted documents to FINRA that gave the false
appearance that he had contemporaneously reviewed those documents when he had not
done so. As a result of this conduct, Rast violated Municipal Securities Rulemaking
Board (MSRB) Rule G-17.
Additionally, in two municipal bond transactions, Rast violated MSRB Rule G-17
through his failure to ensure that CFGCM made proper disclosures of certain
potential material conflicts of interest
How To Spot A Fraud Finance Advisor (Infographic)
Help For Victims Of Kevin Paul Rast
If you have lost funds because of misrepresentation, unsuitable investment, or unsuitable investment strategy from Kevin Paul Rast. Then you can take legal action and get justice. Fraud, Malpractice & dereliction of duty should not be taken lightly, especially in this industry. We highly suggest that you notify authorities or seek legal action if your financial advisor or brokerage firm fails to abide by FINRA’s rules are regulations.
Similar review: GMS Group
Financial advisors are regulatory & legally obligated to suggest (recommend) the most suitable investments/investment strategies to their clients. Their suggestions should have their client’s best interests and should be appropriate for their client’s goals and needs. Similarly, the brokerage firm which hires financial advisors also has a regulatory & legal obligation to keep a close watch and supervise their Financial Advisors’ practices & behavior. They need to make sure that the financial advisor is not being manipulative or having an unreasonable bias towards certain investments. If the financial advisor and/or the brokerage firm breaches these duties, then the client/customer may be entitled to a full or partial recovery of their losses.
Financial advisors need to have the interest of their clients when giving suggestions related to investments and investment strategies. Reasonable basis suitability requires the advisor to do their best to analyze & identify the risks and rewards associated with their suggested investment and/or investment strategy.
Kevin Paul Rast has been involved in fraudulent activities and is an unsafe professional entity. We strongly recommend you avoid any association with such a shady figure.
- Shady Activity
- Swindling Activity Reported By Clients
- Under Govt. Organization's Radar
- High Risk of Fraud