Prohibited and Unethical Business Practices for Broker-Dealers and Agents
Jeremy Ruiz, a state-registered agent with a broker-dealer, recommends a private placement offering in a startup technology company to a client. The client, a retired schoolteacher, has a net worth of $2 million (excluding primary residence) and earns an annual pension of $50,000. Jeremy confirms the client meets the federal definition of an "accredited investor." He thoroughly explains the illiquidity, high-risk nature, and potential for total loss associated with the private placement, and the client acknowledges understanding. However, the investment would represent 25% of the client's total liquid assets, which are primarily concentrated in a diversified mutual fund portfolio. The client's stated investment objective is moderate growth with income preservation.
Under the Uniform Securities Act, which of the following represents Jeremy's most significant ethical or prohibited practice in this scenario?