Preview
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022
Exhibit A
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022
NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022
BEFORE THE FINANCIAL INDUSTRY REGULATORY AUTHORITY
RBC WEALTH MANAGEMENT, a FINRA No. ____________
division of RBC CAPITAL MARKETS,
LLC,
Claimant, STATEMENT OF CLAIM
vs.
David Weigel,
Respondent.
I. INTRODUCTION
1. RBC Wealth Management, a division of RBC Capital Markets, LLC
(“RBC” or the “Company”), brings this action, pursuant to Rule 13200(a) of the FINRA
Code of Arbitration Procedure, to obtain repayment of Promissory Notes received from
its former employee, David Weigel, CRD #2634533 (“Weigel”).
2. As is customary within the financial services industry, in order to assist an
employee’s transition to a new firm and as a recruitment and retention inducement, the
employee often receives a loan secured by a Promissory Note. The loan is generally
immediately due and payable in full in the event the employee leaves for any reason prior
to the maturity date. Under such a circumstance, the employee is obliged to repay the
outstanding balance of the loan, plus accrued interest. Weigel received five such loans
from RBC, and he subsequently failed to repay the loans following his resignation from
RBC on August 17, 2020. RBC therefore seeks an award compensating RBC for the
outstanding principal balances, interest, costs, and reasonable attorneys’ fees.
Exhibit A
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II. STATEMENT OF FACTS
3. On December 6, 2013, Weigel entered into an Employment Agreement
with RBC. (Exhibit 1.) Among other types of compensation, Weigel’s Employment
Agreement provided him with an initial forgivable loan.
4. On December 6, 2013, Weigel executed the first of five promissory notes
with RBC. (Id.) Weigel executed four additional promissory notes on or about February
10, 2015 (Exhibit 2), February 10, 2016 (Exhibit 3), February 8, 2017 (Exhibit 4), and
February 9, 2018 (Exhibit 5) (collectively referenced as the “Notes”). In addition to the
Employment Agreement, Weigel also executed Loan Agreements related to the February
10, 2015, February 10, 2016, February 8, 2017, and February 9, 2018 Notes. 1
5. As relevant here, the key term in each of the Notes is, “If [Weigel’s]
employment by RBC is terminated, for any reason, the unpaid balance of the principal
sum, plus accrued interest, shall be due and payable as of the date of the termination of
employment.” (See Exhibits 1-5.) Relatedly, as long as Weigel remained continuously
employed with RBC, the Company agreed to forgive a portion of the Notes each month.
(Id.)
6. For the December 6, 2013, Note, RBC agreed to loan Weigel $1,063,392 at
an interest rate of 1.63%. Based on a non-linear amortization schedule, RBC forgave a
portion of the Note each month so long as Weigel remained continuously employed at
1
Weigel’s employment agreement and the loan agreement are collectively referred
to as the “Agreements.”
2
Exhibit A
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RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $329,651.52 in
unpaid principal, while interest accrues at $14.72 per day.
7. For the February 10, 2015, Note, RBC agreed to loan Weigel $297,348 at
an interest rate of 1.68%. Based on a non-linear amortization schedule, RBC forgave a
portion of the Note each month so long as Weigel remained continuously employed at
RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $118,388.70 in
unpaid principal, while interest accrues at $5.45 per day.
8. For the February 10, 2016, Note, RBC agreed to loan Weigel $309,085 at
an interest rate of 1.8%. Based on a non-linear amortization schedule, RBC forgave a
portion of the Note each month so long as Weigel remained continuously employed at
RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $160,266.20 in
unpaid principal, while interest accrues at $7.90 per day.
9. For the February 8, 2017, Note, RBC agreed to loan Weigel $265,571 at an
interest rate of 2.08%. Based on a non-linear amortization schedule, RBC forgave a
portion of the Note each month so long as Weigel remained continuously employed at
RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $167,211.40 in
unpaid principal, while interest accrues at $9.53 per day.
10. For the February 9, 2018, Note, RBC agreed to loan Weigel $461,887 at an
interest rate of 2.29%. Based on a non-linear amortization schedule, RBC forgave a
portion of the Note each month so long as Weigel remained continuously employed at
3
Exhibit A
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RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $342,138.56 in
unpaid principal, while interest accrues at $21.47 per day.
11. The Notes all cautioned that if Weigel’s “employment by RBC is
terminated, for any reason, the unpaid balance of the principal sum, plus accrued interest,
shall be due and payable as of the date of the termination of employment.” (See
Exhibits 1-5.) Each Agreement provided a similar warning. (See id.)
12. Weigel resigned from RBC on August 17, 2020 to start a new, independent
Registered Investment Advisory firm. At the time of his resignation, the unforgiven
portion of the five Notes totaled $1,117,656.38, and it became immediately due and
payable on that date.
13. On August 20, 2020 and December 3, 2020, RBC sent Weigel letters
demanding re-payment of the loans. Weigel has not repaid the outstanding principal
balance, and as such, remains in default on the Notes.
14. Each Note also requires Weigel to pay all costs of collection upon default,
including reasonable attorneys’ fees.
III. RELIEF REQUESTED
15. By reason of the foregoing, Weigel has breached his contractual obligations
to RBC and has been unjustly enriched. Accordingly, WHEREFORE, Claimant requests
the Panel enter an award in its favor as follows:
4
Exhibit A
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a. Ordering Weigel to pay $329,651.52 on the December 6, 2013,
Note, plus interest at an annual rate of 1.63% per annum ($14.72 per
diem);
b. Ordering Weigel to pay $118,388.70 on the February 10, 2015,
Note, plus interest at an annual rate of 1.68% per annum ($5.45 per
diem);
c. Ordering Weigel to pay $160,266.20 on the February 10, 2016,
Note, plus interest at an annual rate of 1.80% per annum ($7.90 per
diem);
d. Ordering Weigel to pay $167,211.40 on the February 8, 2017, Note,
plus interest at an annual rate of 2.08% per annum ($9.53 per diem);
e. Ordering Weigel to pay $342,138.56 on the February 9, 2018, Note,
plus interest at an annual rate of 2.29% per annum ($21.47 per
diem);
f. Ordering Weigel to pay RBC’s costs and expenses of this
proceeding, including reasonable attorneys’ fees; and
g. Awarding any further relief as the Panel deems fair and just.
5
Exhibit A
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Dated: December 16, 2020 DORSEY & WHITNEY LLP
By s/ Michael Rowe
Michael E. Rowe (MN #0392598)
rowe.michael@dorsey.com
Caitlin L.D. Hull (MN #0398394)
hull.caitlin@dorsey.com
50 South Sixth Street, Suite 1500
Minneapolis, MN 55402-1498
Telephone: (612) 340-2600
Facsimile: (612) 340-2868
Attorneys for Claimant
RBC WEALTH MANAGEMENT, a
division of RBC CAPITAL MARKETS,
LLC
6
Exhibit A
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NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022
CERTIFICATE OF SERVICE
I, Michael Rowe, certify that on December 16, 2020, I served via FINRA’s portal
true and correct copies of:
1. Claimant RBC Wealth Management’s, a division of RBC Capital
Markets, LLC, (“RBC”), Statement of Claim;
2. RBC’s FINRA Arbitration Submission Agreement; and
3. Certificate of Service.
Dated: December 16, 2020 s/ Michael Rowe
Michael E. Rowe
7
Exhibit A
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Exhibit 1
Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit 2
Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit 3
Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit 4
Exhibit A
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Exhibit A
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Exhibit A
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Exhibit A
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Exhibit 5
Exhibit A
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Exhibit A
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Exhibit A
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022
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Exhibit A
Preview
FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 BEFORE THE FINANCIAL INDUSTRY REGULATORY AUTHORITY RBC WEALTH MANAGEMENT, a FINRA No. ____________ division of RBC CAPITAL MARKETS, LLC, Claimant, STATEMENT OF CLAIM vs. David Weigel, Respondent. I. INTRODUCTION 1. RBC Wealth Management, a division of RBC Capital Markets, LLC (“RBC” or the “Company”), brings this action, pursuant to Rule 13200(a) of the FINRA Code of Arbitration Procedure, to obtain repayment of Promissory Notes received from its former employee, David Weigel, CRD #2634533 (“Weigel”). 2. As is customary within the financial services industry, in order to assist an employee’s transition to a new firm and as a recruitment and retention inducement, the employee often receives a loan secured by a Promissory Note. The loan is generally immediately due and payable in full in the event the employee leaves for any reason prior to the maturity date. Under such a circumstance, the employee is obliged to repay the outstanding balance of the loan, plus accrued interest. Weigel received five such loans from RBC, and he subsequently failed to repay the loans following his resignation from RBC on August 17, 2020. RBC therefore seeks an award compensating RBC for the outstanding principal balances, interest, costs, and reasonable attorneys’ fees. Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 II. STATEMENT OF FACTS 3. On December 6, 2013, Weigel entered into an Employment Agreement with RBC. (Exhibit 1.) Among other types of compensation, Weigel’s Employment Agreement provided him with an initial forgivable loan. 4. On December 6, 2013, Weigel executed the first of five promissory notes with RBC. (Id.) Weigel executed four additional promissory notes on or about February 10, 2015 (Exhibit 2), February 10, 2016 (Exhibit 3), February 8, 2017 (Exhibit 4), and February 9, 2018 (Exhibit 5) (collectively referenced as the “Notes”). In addition to the Employment Agreement, Weigel also executed Loan Agreements related to the February 10, 2015, February 10, 2016, February 8, 2017, and February 9, 2018 Notes. 1 5. As relevant here, the key term in each of the Notes is, “If [Weigel’s] employment by RBC is terminated, for any reason, the unpaid balance of the principal sum, plus accrued interest, shall be due and payable as of the date of the termination of employment.” (See Exhibits 1-5.) Relatedly, as long as Weigel remained continuously employed with RBC, the Company agreed to forgive a portion of the Notes each month. (Id.) 6. For the December 6, 2013, Note, RBC agreed to loan Weigel $1,063,392 at an interest rate of 1.63%. Based on a non-linear amortization schedule, RBC forgave a portion of the Note each month so long as Weigel remained continuously employed at 1 Weigel’s employment agreement and the loan agreement are collectively referred to as the “Agreements.” 2 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $329,651.52 in unpaid principal, while interest accrues at $14.72 per day. 7. For the February 10, 2015, Note, RBC agreed to loan Weigel $297,348 at an interest rate of 1.68%. Based on a non-linear amortization schedule, RBC forgave a portion of the Note each month so long as Weigel remained continuously employed at RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $118,388.70 in unpaid principal, while interest accrues at $5.45 per day. 8. For the February 10, 2016, Note, RBC agreed to loan Weigel $309,085 at an interest rate of 1.8%. Based on a non-linear amortization schedule, RBC forgave a portion of the Note each month so long as Weigel remained continuously employed at RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $160,266.20 in unpaid principal, while interest accrues at $7.90 per day. 9. For the February 8, 2017, Note, RBC agreed to loan Weigel $265,571 at an interest rate of 2.08%. Based on a non-linear amortization schedule, RBC forgave a portion of the Note each month so long as Weigel remained continuously employed at RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $167,211.40 in unpaid principal, while interest accrues at $9.53 per day. 10. For the February 9, 2018, Note, RBC agreed to loan Weigel $461,887 at an interest rate of 2.29%. Based on a non-linear amortization schedule, RBC forgave a portion of the Note each month so long as Weigel remained continuously employed at 3 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 RBC. As of the date of Weigel’s resignation at RBC, he owed RBC $342,138.56 in unpaid principal, while interest accrues at $21.47 per day. 11. The Notes all cautioned that if Weigel’s “employment by RBC is terminated, for any reason, the unpaid balance of the principal sum, plus accrued interest, shall be due and payable as of the date of the termination of employment.” (See Exhibits 1-5.) Each Agreement provided a similar warning. (See id.) 12. Weigel resigned from RBC on August 17, 2020 to start a new, independent Registered Investment Advisory firm. At the time of his resignation, the unforgiven portion of the five Notes totaled $1,117,656.38, and it became immediately due and payable on that date. 13. On August 20, 2020 and December 3, 2020, RBC sent Weigel letters demanding re-payment of the loans. Weigel has not repaid the outstanding principal balance, and as such, remains in default on the Notes. 14. Each Note also requires Weigel to pay all costs of collection upon default, including reasonable attorneys’ fees. III. RELIEF REQUESTED 15. By reason of the foregoing, Weigel has breached his contractual obligations to RBC and has been unjustly enriched. Accordingly, WHEREFORE, Claimant requests the Panel enter an award in its favor as follows: 4 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 a. Ordering Weigel to pay $329,651.52 on the December 6, 2013, Note, plus interest at an annual rate of 1.63% per annum ($14.72 per diem); b. Ordering Weigel to pay $118,388.70 on the February 10, 2015, Note, plus interest at an annual rate of 1.68% per annum ($5.45 per diem); c. Ordering Weigel to pay $160,266.20 on the February 10, 2016, Note, plus interest at an annual rate of 1.80% per annum ($7.90 per diem); d. Ordering Weigel to pay $167,211.40 on the February 8, 2017, Note, plus interest at an annual rate of 2.08% per annum ($9.53 per diem); e. Ordering Weigel to pay $342,138.56 on the February 9, 2018, Note, plus interest at an annual rate of 2.29% per annum ($21.47 per diem); f. Ordering Weigel to pay RBC’s costs and expenses of this proceeding, including reasonable attorneys’ fees; and g. Awarding any further relief as the Panel deems fair and just. 5 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Dated: December 16, 2020 DORSEY & WHITNEY LLP By s/ Michael Rowe Michael E. Rowe (MN #0392598) rowe.michael@dorsey.com Caitlin L.D. Hull (MN #0398394) hull.caitlin@dorsey.com 50 South Sixth Street, Suite 1500 Minneapolis, MN 55402-1498 Telephone: (612) 340-2600 Facsimile: (612) 340-2868 Attorneys for Claimant RBC WEALTH MANAGEMENT, a division of RBC CAPITAL MARKETS, LLC 6 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 CERTIFICATE OF SERVICE I, Michael Rowe, certify that on December 16, 2020, I served via FINRA’s portal true and correct copies of: 1. Claimant RBC Wealth Management’s, a division of RBC Capital Markets, LLC, (“RBC”), Statement of Claim; 2. RBC’s FINRA Arbitration Submission Agreement; and 3. Certificate of Service. Dated: December 16, 2020 s/ Michael Rowe Michael E. Rowe 7 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit 1 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit 2 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit 3 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit 4 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit 5 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A FILED: NEW YORK COUNTY CLERK 09/06/2022 01:51 PM INDEX NO. 653224/2022 NYSCEF DOC. NO. 2 RECEIVED NYSCEF: 09/06/2022 Exhibit A