1 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION 

SECURITIES AND EXCHANGE 

COMMISSION, 

Plaintiff, 

v. 

JESUS RODRIGUEZ, 

Defendant. 

Civil Action No. ________ 

JURY TRIAL DEMANDED 

COMPLAINT 

Plaintiff Securities and Exchange Commission (the “Commission”) alleges the following 

for its Complaint against Defendant Jesus Rodriguez (“Rodriguez” or “Defendant”): 

SUMMARY 

1. From approximately 2014 through 2021 (the “Relevant Period”), Rodriguez

engaged in a fraudulent scheme to misappropriate more than $3.4 million from the accounts of at 

least ten investors (the “Investors”) while he served as their registered representative and/or 

investment adviser representative at a large financial institution dually-registered with the 

Commission as a broker-dealer and investment adviser (“Firm A”). 

2. Rodriguez carried out his misappropriation scheme by initiating fraudulent

disbursements of funds primarily through unauthorized ACH transfers, wire transfers, and cash 

journal transfers to other accounts at Firm A.1 

1

 ACH transfers are electronic, bank-to-bank money transfers processed through the Automated 

Clearing House (ACH) Network. 

3:24-cv-27

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3. In a number of instances, Rodriguez misappropriated from the Investors’ accounts 

by incurring unauthorized indebtedness collateralized by their securities accounts. In other 

instances, Rodriguez sold securities from Investors’ accounts shortly before misappropriating all 

or part of the sales proceeds. 

4. Rodriguez was also an investment adviser to three of the defrauded Investors and 

he breached his fiduciary duties to them by misappropriating their funds and/or by making false 

statements to them. 

VIOLATIONS 

5. By virtue of the foregoing conduct and as alleged further herein, Defendant has 

violated Section 10(b) of the Securities Exchange Act of 1934 (“Exchange Act”) [15 U.S.C. §§ 

78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5], and Sections 206(1) and 206(2) of 

the Investment Advisers Act of 1940 (“Advisers Act”) [15 U.S.C. §§ 80b-6(1) and (2)]. 

6. Unless Defendant is restrained and enjoined, he will engage in the acts, practices, 

transactions, and courses of business set forth in this Complaint or in acts, practices, transactions, 

and courses of business of similar type and object. 

NATURE OF THE PROCEEDINGS AND RELIEF SOUGHT 

7. The Commission brings this action pursuant to the authority conferred upon it by 

Section 21(d) of the Exchange Act [15 U.S.C. § 78u(d)] and Section 209(d) and 209(e) of the 

Advisers Act [15 U.S.C. §§ 80b-9(d) and (e)]. 

8. The Commission seeks a final judgment: (a) permanently enjoining Defendant 

from violating the federal securities laws and rules this Complaint alleges he has violated, 

pursuant to Section 21(d)(1) of the Exchange Act and Section 209(d) of the Advisers Act [15 

U.S.C. § 78u(d)(1) and 15 U.S.C. § 80b-9(d)]; (b) ordering Defendant to disgorge all ill-gotten 

gains he has received as a result of the violations alleged here and to pay prejudgment interest 

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thereon, pursuant to Exchange Act Sections 21(d)(3), 21(d)(5), and 21(d)(7) [15 U.S.C. §§ 

78u(d)(3), 78u(d)(5), and 78u(d)(7)]; (c) ordering Defendant to pay civil money penalties 

pursuant to Exchange Act Section 21(d)(3) [15 U.S.C. § 78u(d)(3)] and Advisers Act Section 

209(e) [15 U.S.C. § 80b-9(e)]; and (d) ordering any other and further relief the Court may deem 

just and proper. 

JURISDICTION AND VENUE

9. This Court has jurisdiction over this action pursuant to Sections 21(d), 21(e), and 

27 of the Exchange Act [15 U.S.C. § 78aa] and Section 214 of the Advisers Act [15 U.S.C. § 

80b-14]. 

10. In connection with the transaction, acts, practices, and courses of business 

described in this Complaint, Defendant, directly and indirectly, made use of the means or 

instrumentalities of interstate commerce, or of the mails, or of the means and instruments of 

transportation or communication in interstate commerce. 

11. Venue lies in this District under Section 27 of the Exchange Act [15 U.S.C. § 

78aa] and Section 214 of the Advisers Act [15 U.S.C. § 80b-14]. Certain of the acts, practices, 

transactions, and courses of business described in this Complaint occurred within the El Paso 

Division of the Western District of Texas. For example, during the Relevant Period, Rodriguez 

resided in El Paso and worked in the El Paso branch of Firm A. 

DEFENDANT 

12. Rodriguez, age 44, is a Mexican citizen residing in El Paso, Texas. In 2008, after 

working at another dually-registered entity from 2004 through 2007, Rodriguez joined Firm A as 

a registered representative and investment adviser representative at its El Paso, Texas branch. 

Rodriguez served in that role at Firm A until 2021, when he was terminated following the 

discovery of the conduct alleged in this complaint. Rodriguez has held FINRA Series 7 and 66 

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licenses. Following his departure from Firm A, FINRA accepted a letter of acceptance, waiver, 

and consent from Rodriguez, barring Rodriguez from associating with any FINRA member firm. 

13. Rodriguez is presently facing criminal prosecution by authorities in El Paso, 

based on allegations that he misappropriated funds from the Firm A account of an investor. 

FACTS 

I. Background 

14. While employed at Firm A, Rodriguez recruited customers and clients, many of 

whom resided in Mexico, to open brokerage and/or advisory accounts with Firm A for which 

Rodriguez served as the assigned registered representative and/or investment adviser 

representative. 

15. Rodriguez’s brokerage customers and/or advisory clients trusted Rodriguez to 

manage their money and securities at Firm A. Rodriguez exploited this trust to steal from them. 

16. From approximately March 2014 through July 2021, Rodriguez misappropriated a 

gross total of at least $3.4 million from the ten Investors: 

Investor Approximate (Gross) 

Unauthorized Transfers

A $675,000

B $600,000

C $520,000

D $440,000

E $380,000

F $335,000

G $295,000

H $124,000

I $123,000

J $28,000

Approximate 

Total 

$3,475,000 

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17. None of the Investors authorized Rodriguez to withdraw these funds from their 

accounts or to use their money for Rodriguez’s own purposes. 

18. Rodriguez convinced certain of the Investors, including Investors D, E, and H, to 

direct their account statements sent by Firm A to a mailing address under Rodriguez’s control. 

Those Investors relied on Rodriguez to relay information to them about their accounts. 

19. Certain other Investors similarly relied on Rodriguez to provide information to 

them about their accounts because they had limited access to the locations that they selected to 

have their account statements sent, and/or they had language barriers that prevented them from 

understanding Firm A’s statements in English, and/or they did not regularly review their account 

statements. 

II. Rodriguez’s Primary Methods to Misappropriate from the Investors’ Accounts 

20. Rodriguez misappropriated from the ten Investors using three primary methods. 

First, Rodriguez initiated unauthorized wire transfers from Investors’ accounts by falsifying 

internal forms and letters of authorization. Second, Rodriguez initiated unauthorized cash 

journal transfers from Investors’ accounts to certain other accounts at Firm A. Third, Rodriguez 

initiated unauthorized ACH transfers of funds from Investors’ accounts that primarily were to 

pay balances on Rodriguez’s credit cards. 

A. Unauthorized Wire Transfers 

21. Between approximately March 2014 and July 2021, Rodriguez fraudulently 

misappropriated a total of more than $1.7 million through more than seventy unauthorized wire 

transfers from the accounts of Investors A, C, D, E, G, and I, for Rodriguez’s own benefit. 

22. For almost every unauthorized wire, Rodriguez falsified Firm A’s internal 

authorization forms by representing that he had received a verbal request for the wire from the 

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Investor. Rodriguez, or Rodriguez’s assistant acting at his direction, filled out and submitted the 

forms based on Rodriguez’s false assertion that the Investor had verbally requested the wire 

transfer. Rodriguez also falsified reasons for the wire transfers on these forms, such as 

“equipment for business purchase,” “loan balance payoff,” “payment of estate planning and 

business services,” “professional services,” and “property taxes,” among others. 

23. None of the Investors requested the wires or otherwise gave permission to 

Rodriguez to make these wire transfers. 

24. Rodriguez directed these unauthorized third-party wires for this own benefit. 

25. For example, Rodriguez directed more than $350,000 in twenty separate wires 

from the accounts of Investors C, D, and G to his mother’s bank account. Rodriguez and/or his 

mother, in turn, paid credit card bills and car payments from this account, withdrew cash from 

ATMs, and transferred some funds on to Rodriguez’s own bank account. 

26. Rodriguez also transferred $325,400 in fourteen separate wires from the accounts 

of Investors A, D, and G to his then-wife and/or a company controlled by her. 

27. In one instance, Rodriguez was unable to use a falsified verbal request 

authorization form because it exceeded Firm A’s dollar limit on verbal wire transfers. Rodriguez 

instead forged a written authorization letter and fraudulently submitted it to Firm A to process. 

28. Specifically, in December 2018, Rodriguez initiated a $125,000 wire transfer 

from Investor C’s account to pay for Rodriguez’s purchase of a Lamborghini. Without Investor 

C’s authorization or knowledge, Rodriguez created a falsified written authorization letter 

requesting the transfer “to finalize the purchase of [] commercial property” and applied an image 

of Investor C’s signature to the authorization letter without her consent. 

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29. Rodriguez also created a fake email account in order to impersonate Investor C 

and convince Firm A to process the wire. Rodriguez used the fake email account he created to 

send the forged letter to his email account at Firm A, from which he forwarded it within Firm A 

and requested that Firm A process the wire. Firm A processed the wire transfer. 

B. Unauthorized Cash Journal Transfers 

30. Between approximately March 2016 and June 2021, Rodriguez also 

misappropriated at least $1.3 million via dozens of unauthorized cash journal transfers from the 

accounts of Investors B, C, D, E, F, G, H, I, J to other accounts at Firm A. 

31. As with Rodriguez’s falsification of internal Firm A authorization forms for 

verbal wire transfer client requests (as alleged in paragraph 23, above), Rodriguez falsified 

similar internal Firm A authorization forms for the purported verbally-requested journal 

transfers. 

32. Rodriguez, or Rodriguez’s assistant acting at his direction, filled out and 

submitted the forms based on Rodriguez’s false representation that he had received a verbal 

request from the Investor for the journal transfer. Rodriguez also similarly provided a fake 

explanation on the form for the journal transfer, including “stock purchase,” “vacation rental,” 

“estate planning and taxes,” “capital contribution,” and “professional services,” among others. 

33. None of the Investors requested the cash journal transfers or otherwise gave 

permission to Rodriguez to make these transfers. 

34. In many instances, Rodriguez directed these fraudulent transfers to the accounts 

of his relatives and/or associates. 

35. For example, Rodriguez initiated unauthorized journal transfers to move more 

than $375,000 from the Firm A accounts of Investors B and Eto a Firm A account in the name of 

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a corporate entity owned by Rodriguez’s mother. Rodriguez and/or his mother used this account 

to (among other things) wire funds to himself and his then-wife, and to pay credit card bills. 

36. Similarly, in December 2019, Rodriguez also initiated an unauthorized journal 

transfer to move approximately $8,000 from the Firm A account of Investor G to the account of a 

relative of Rodriguez’s then-wife. 

C. Unauthorized ACH Transfers 

37. Between approximately November 2018 and July 2021, Rodriguez stole more 

than $400,000 from the accounts of Investors B, C, D, E, F, and G through more than 100 

unauthorized ACH transfers. 

38. Rodriguez initiated nearly all of the unauthorized ACH transfers through credit 

card companies to withdraw funds from the Investors’ accounts at Firm A to make payments on 

credit cards for Rodriguez’s benefit. In a small number of instances, Rodriguez initiated 

unauthorized ACH transfers through an online payment application to withdraw funds from an 

Investor’s account to his own account with that online payment application. 

39. To initiate each of these unauthorized ACH transfers, Rodriguez entered the 

account information for an Investor’s account at Firm A as the payment source from which to 

withdraw funds using the ACH system. In initiating these ACH transfers at the credit card 

companies or online payment application, Rodriguez falsely represented to the credit-card 

company or online payment application that he was authorized to debit the designated accounts. 

40. The credit card companies or online payment application, in turn, electronically 

transmitted those payment instructions to Firm A using the ACH system, which Firm A then 

processed by debiting the Investor’s account at Firm A and transmitting the funds to the credit 

card company or online payment application. In doing so, Rodriguez took advantage of policies 

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at Firm A that did not require an authorization from the Firm A account holder for ACH transfers 

initiated by third-party financial institutions, such as credit card companies. 

41. Using this method, Rodriguez misappropriated from the Investors’ accounts to 

pay credit card balances with a dozen different credit card companies. 

42. None of the Investors whose accounts were debited for these ACH transfers 

authorized Rodriguez to make these ACH transfers or to use his or her money for these purposes. 

III. Rodriguez’s Unauthorized Use of Securities-Backed Loans and Securities Sales 

Proceeds to Fund His Misappropriation 

43. Rodriguez funded much of his misappropriation from Investors A, B, C, D, E, G, 

I, and J by initiating unauthorized borrowing against these Investors’ securities accounts. 

44. Rodriguez misappropriated from Investors A, C, D, G, and I by making 

withdrawals from loan accounts or lines of credit at Firm A collateralized by the securities 

accounts of the Investor. 

45. Similarly, Rodriguez misappropriated from Investors B, E, and J by using a 

margin feature on that Investor’s securities account to make unauthorized withdrawals. 

46. Each of the unauthorized withdrawals alleged in paragraphs 43 through 45 above 

from Investors’ loan accounts or lines of credit at Firm A, or by using margin, was secured by 

pledges of the securities in the Investors’ respective securities accounts. The pledge of securities 

is deemed to be a “sale” for purposes of Section 10(b) of the Exchange Act and Rule 10b-5 

thereunder. 

47. In addition, as part of his scheme, Rodriguez in some instances misappropriated 

from Investors D, E, F, and G, by directly effecting securities sales in their accounts to generate 

cash and misappropriating all or a portion of the proceeds within three days thereafter. 

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48. All of Rodriguez’s unauthorized transfers from Investor F’s account were funded 

by automatic sales of Investor B’s holdings of a money-market securities fund. 

49. There were at least 5 instances, in which Rodriguez misappropriated a total of 

$84,000 from Investor E, that took place within three days of a securities sale. Rodriguez 

similarly misappropriated a total of more than $20,000 from Investor G and more than $12,000 

from Investor D through unauthorized transfers that took place within three days of a securities 

sale in their respective accounts. 

IV. Rodriguez Breached His Fiduciary Duty to His Advisory Clients 

50. Rodriguez was an investment adviser to Investors D, E, and H. 

51. In that capacity, Rodriguez advised Investors D, E, and H, with respect to 

investments in securities and was compensated for these services through his receipt of a portion 

of the advisory fees these Investors paid to Firm A for their advisory accounts. 

52. As an investment adviser to Investors D, E, and H, Rodriguez owed an affirmative 

fiduciary duty of utmost good faith to them. In violation of that duty, Rodriguez exploited the 

trust of these Investors to misappropriate from their advisory and/or brokerage accounts at Firm 

A. 

53. Rodriguez misappropriated approximately $440,000 from Investor D’s accounts 

at Firm A, all of which occurred while Rodriguez served as an investment adviser to Investor D. 

54. Rodriguez misappropriated approximately $380,000 from Investor E’s accounts at 

Firm A, all of which occurred while Rodriguez served as an investment adviser to Investor E. 

55. Rodriguez misappropriated approximately $124,000 from Investor H’s accounts 

at Firm A, at least $10,000 of which was during the time period in which Investor H was an 

advisory client of Rodriguez. 

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V. Rodriguez Engaged in Additional Deceptive Conduct 

56. Rodriguez concealed his fraud from the Investors through other deceptive means. 

57. For example, Rodriguez convinced Investor E and her husband to set up and fund 

an account at Firm A through a corporate entity, and to direct the account statements for the 

entity to be sent to a P.O. Box under Rodriguez’s control. 

58. Knowing that Investor E was not going to receive account statements, Rodriguez 

then arranged for unauthorized transfers from Investor E’s account at Firm A for his own benefit. 

59. For instance, on October 12, 2018, Rodriguez caused an unauthorized wire of 

$25,000 to be sent from Investor E’s account at Firm A to another company in which Rodriguez 

was an investor. To induce Firm A to process this wire, Rodriguez falsely indicated on a “verbal 

wire processing form” that Investor E had personally requested the transfer to fund a “capital 

contribution.” 

60. However, Investor E had not requested the transfer. In fact, when Firm A sent 

Investor E an email notification that her “wire transfer request” had been processed, Investor E 

was confused, as she had not requested any transfer. Investor E forwarded this message to 

Rodriguez and asked him about it. Rodriguez falsely assured her that he would “take care of it.” 

Rodriguez not only misled Investor E by failing to disclose that he had initiated the transfer but 

also did not repay the money. 

61. Because Investor E’s account statements were directed to a P.O. Box under 

Rodriguez’s control, she was unable to review these account statements and identify that no 

refund or credit of the amount was posted to her account. Over time, Investor E repeatedly 

requested that Rodriguez share her Firm A account statements with her, but he made excuses, 

and did not do so. 

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62. By lying to Investor E, and withholding her account statements from her, 

Rodriguez was able to misappropriate a total of $380,000 from Investor E between January 2017 

and September 2020. 

63. As another example, after Investor J noticed that cash had been taken out of her 

account and asked Rodriguez about it, Rodriguez lied and told her it had been an error. In an 

attempt to conceal his misconduct, Rodriguez then moved $16,460 from another account to 

partially repay Investor J. 

64. To further perpetuate his scheme and conceal his misconduct, Rodriguez also lied 

to Firm A when responding to inquiries about some of the Investors’ large loan obligations that 

Rodriguez had incurred in their accounts to fund his misappropriation from them, as alleged in 

paragraphs 44 through 46 above. 

65. For example, in July 2018, Firm A’s leverage review personnel asked Rodriguez 

about the balance owed by Investor G. Rodriguez falsely represented that Investor G had 

“borrowed funds to acquire commercial real estate” and that Rodriguez was “comfortable with 

the client’s capacity and ability to pay the loan off.” Rodriguez made these misrepresentations 

while knowing that Rodriguez incurred the loan balance at issue without Investor F’s knowledge 

or authorization. 

66. Firm A’s leverage review personnel followed up with Rodriguez to discuss the 

loan balance owed by Investor G again in September 2019, August 2020, and December 2020; 

each time, Rodriguez made similar misrepresentations about the purpose of the loan and 

provided false assurances of Investor G’s supposed intention to repay it. 

67. Similarly, Rodriguez lied in August 2019 when Firm A’s leverage review 

personnel asked him about the large balance owed by Investor C. Rodriguez falsely responded 

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that Investor C had incurred the debt to purchase commercial real estate, that she was “aware of 

the risk of leverage and is comfortable with it,” and that she was planning to pay off the loan 

once she had sold her real estate. In fact, most of the balance that Investor C purportedly owed 

Firm A as of August 2019 was attributable to Rodriguez’s misappropriations from Investor C’s 

accounts, including his misappropriation to purchase a Lamborghini for himself as alleged in 

paragraphs 28 and 29, above. 

VI. Rodriguez Used Misappropriated Funds to Support His Lifestyle 

68. Rodriguez used funds that he misappropriated from the Investors to support his 

opulent lifestyle, which included the purchase and operation of multiple luxury automobiles, 

including a Lamborghini, multiple BMWs, a Land Cruiser, a Land Rover, and a Toyota Yaris. 

Rodriguez routinely traveled from El Paso to Austin to race these cars on a private track. 

69. As detailed above, Rodriguez also incurred hundreds of thousands of dollars in 

credit card bills, some of which he paid directly from Firm A investor accounts, and others of 

which he paid after transferring money to his mother’s bank account. 

70. Rodriguez also transferred $325,000 to his then-wife from Investors at Firm A 

without authorization. 

FIRST CLAIM FOR RELIEF 

Violations of Exchange Act Section 10(b) and Rule 10b-5 Thereunder 

71. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 70. 

72. Rodriguez, directly or indirectly, singly or in concert, in connection with the 

purchase or sale of securities and by the use of means or instrumentalities of interstate 

commerce, or the mails, or the facilities of a national securities exchange, knowingly or 

recklessly has: (i) employed one or more devices, schemes or artifices to defraud; and/or (ii) 

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made one or more untrue statements of a material fact or omitted to state one or more material 

facts necessary in order to make the statements made, in light of the circumstances under which 

they were made, not misleading; and/or (iii) engaged in one or more acts, practices, or courses of 

business which operated or would operate as a fraud or deceit upon other persons. 

73. By reason of the foregoing, Rodriguez, directly or indirectly, singly or in concert, 

has violated and, unless enjoined, will again violate Exchange Act Section 10(b) [15 U.S.C. § 

78j(b)] and Rule 10b-5 thereunder [17 C.F.R. § 240.10b-5]. 

SECOND CLAIM FOR RELIEF 

Violations of Advisers Act Section 206 

74. The Commission re-alleges and incorporates by reference here the allegations in 

paragraphs 1 through 70. 

75. At all relevant times, Rodriguez was an investment adviser under Section 202(11) 

of the Advisers Act [15 U.S.C. § 80b-2(11)]. 

76. Rodriguez, by use of the mails or any means or instrumentalities of interstate 

commerce, directly or indirectly has: (i) knowingly or recklessly employed one or more devices, 

schemes, or artifices to defraud any client or prospective client; and/or (ii) knowingly, recklessly, 

or negligently engaged in one or more transactions, practices, and courses of business which 

operated or would operate as a fraud or deceit upon any client or prospective client. 

77. By reason of the foregoing, Rodriguez, directly or indirectly, singly or in concert, 

has violated and, unless enjoined, will again violate Sections 206(1) and (2) of the Advisers Act 

[15 U.S.C. §§ 80b-6(1) and 80b-6(2)]. 

PRAYER FOR RELIEF 

WHEREFORE, the Commission respectfully requests that the Court enter a Final 

Judgment: 

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I. 

Permanently enjoining Rodriguez and his agents, servants, employees, and attorneys and 

all persons in active concert or participation with him from violating, directly or indirectly, 

Exchange Act Section 10(b) [15 U.S.C. § 78j(b)], and Rule 10b-5 thereunder [17 C.F.R. § 

240.10b-5], and Advisers Act Sections 206(1) and 206(2) [15 U.S.C. §§ 80b-6(1) and 80b-6(2)]; 

II. 

Ordering Rodriguez to disgorge all ill-gotten gains he received directly or indirectly, with 

pre-judgment interest thereon, as a result of the alleged violations; 

III. 

Ordering Rodriguez to pay civil monetary penalties under Exchange Act Section 21(d)(3) 

[15 U.S.C. § 78u(d)(3)] and Section 209(e) of the Advisers Act [15 U.S.C. § 80b-9(e)]; and 

IV. 

Granting any other and further relief this Court may deem just and proper. 

JURY DEMAND 

The Commission demands a trial by jury. 

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Dated: January 24, 2024 

 

Respectfully submitted, 

/s/ Nicholas Flath 

Nicholas Flath 

Application for admission pro hac vice pending

U.S. SECURITIES AND EXCHANGE COMMISSION 

New York Regional Office 

100 Pearl Street Suite 20-100 

New York, NY 10004-2616 

Tel. (212) 336-9149 

flathn@sec.gov 

Jennifer D. Reece 

Local Counsel 

Texas Bar No. 00796242 

U.S. SECURITIES AND EXCHANGE COMMISSION 

801 Cherry Street, Suite 1900 

Fort Worth, TX 76102 

Tel: (817) 978-6442 

Fax: (817) 978-4927 

reecej@sec.gov

Attorneys for Plaintiff 

Of Counsel 

Antonia M. Apps 

Tejal D. Shah 

Wendy B. Tepperman 

Todd D. Brody 

SECURITIES AND EXCHANGE COMMISSION 

New York Regional Office 

100 Pearl Street, Suite 20-100 

New York, New York 10004-2616 

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