The Financial Industry Regulatory Authority (FINRA) has suspended Zachary Ellis Taylor, a former representative of Oppenheimer, for nine months.

Zachary Ellis Taylor first registered with FINRA in 2012. From August 2020 through June 2023, Taylor was registered as a General Securities Representative through an association with Oppenheimer & Co., Inc. On June 2, 2023, Oppenheimer filed a Uniform Termination Notice for Securities Industry Regulation disclosing that Taylor had been terminated because the firm “was unable to provide sufficient documentary evidence to support his contention that he had authority for all trades in a client’s account.”

From June 2023 through October 2023, Taylor was registered with FINRA through an association with another member firm.

Between August 2020 and June 2023, Taylor recommended that at least three retired senior customers liquidate their diversified portfolios and engage in a speculative options strategy. The customers did not have experience investing in options and had moderate risk tolerances.

Taylor recommended that the customers sell puts, typically large numbers of puts in one underlying security at a time. As time passed, Taylor recommended that the customers sell more of these puts, putting at risk most of the principal value of their accounts.

Taylor also began recommending increasingly risky puts, where the strike price was closer to the trading price. While this strategy initially generated higher premiums for customers, it also increased the likelihood that the put would be exercised.

For instance, one customer was 71 years old and retired when he opened his accounts at Oppenheimer in the fall of 2020. Between September and November 2020, Taylor recommended that he liquidate most of his diversified holdings. In 2021, Taylor recommended that this customer sell puts in a single tech security in his three accounts at Oppenheimer. The customer followed this recommendation and 17 of those put contracts were exercised at a strike price significantly higher than the market price.

The customer was required to buy 1,700 shares of the tech security at a loss of approximately $104.58 per share less than the stock’s trading price as of the date of purchase. As a result of

Taylor’s recommendations, by April 2022, approximately 82% of this retired customer’s holdings at Oppenheimer were concentrated in that single stock. When the accounts were transferred out of Oppenheimer, the customer had approximately $130,000 in realized and unrealized losses resulting from his sales of puts in the stock.

Taylor’s recommendations were not in the customers’ best interest and were unsuitable for them based on their investment profiles.

Therefore, Taylor willfully violated Exchange Act Rule 15/-l(a)(l) and violated FINRA Rules 2360(b)(l9)(A) and Rule 2010.

The respondent consented to a nine-month suspension from associating with any FINRA member in all capacities.

He has submitted a statement of financial condition and demonstrated an inability to pay. In light of his financial status, no monetary sanctions or restitution have been imposed.