Sam Bhushan and Cabin Securities Face Ten Customer Disputes Over Reg D Private Placement Recommendations

May 12, 2026

If you are a current or former client of Sam Bhushan and invested in a Reg D private placement on his recommendation, you should know that his BrokerCheck record now discloses ten reported customer disputes, with one settled and nine currently pending, all arising from real estate securities sold while he was registered with Cabin Securities, Inc. Sam Bhushan (CRD# 4884717) is not currently registered with any broker-dealer; he was last registered with Cabin Securities, Inc., in Irvine, California, from July 2017 through December 2025. According to BrokerCheck, Bhushan also disclosed an outside business activity, doing business as “DSTs 1031 Investments,” with all activity executed through and supervised by Cabin Securities, Inc.

Settlement History

According to BrokerCheck, Bhushan was the subject of a customer complaint regarding a Reg D private placement that asserted causes of action for fraud, misrepresentation, omissions of material facts, unsuitable recommendations, breach of contract, and breach of fiduciary duty. According to BrokerCheck, FINRA Dispute Resolution Case No. 22-02378, filed on October 20, 2022, alleged damages of $150,000.00. According to BrokerCheck, the matter settled on March 30, 2023 for $132,498.00, with Bhushan’s individual contribution recorded as $0.00.

According to BrokerCheck, nine additional customer disputes against Bhushan are currently pending. Across the pending disclosures, the product type is recorded as a Real Estate Security, and the asserted causes of action include fraud, misrepresentation, omissions of material facts, unsuitable recommendations, breach of contract, and breach of fiduciary duty in connection with a Reg D private placement. The pending matters disclosed on Bhushan’s record are:

According to BrokerCheck, FINRA Case No. 26-00718 alleges damages of $3,500,000.00, with notice of arbitration served on April 7, 2026.
According to BrokerCheck, FINRA Case No. 26-00782 alleges damages of $140,000.00, with notice of arbitration served on April 7, 2026.
According to BrokerCheck, FINRA Case No. 26-00452, received on March 3, 2026, alleges damages of $1,695,000.00.
According to BrokerCheck, FINRA Case No. 26-00565, in which notice of arbitration was served on March 12, 2026, alleges damages of $205,000.00.
According to BrokerCheck, FINRA Case No. 26-00769, in which notice of arbitration was served on April 17, 2026, alleges damages of $500,000.00 in a matter for which the customer’s written complaint was received on January 6, 2026.
According to BrokerCheck, FINRA Case No. 25-02780, filed on January 16, 2026 and received on January 20, 2026, alleges damages of $1,021,000.00.
According to BrokerCheck, FINRA Case No. 25-02807, in which notice of arbitration was served on December 30, 2025, alleges damages of $3,400,000.00.
According to BrokerCheck, FINRA Case No. 25-02557, filed on November 21, 2025, alleges damages of $2,025,634.00 in connection with causes of action for common law fraud, unsuitable recommendations, and breach of fiduciary duty.
According to BrokerCheck, FINRA Case No. 25-02355, filed on November 5, 2025, alleges damages of $413,637.00 in connection with a Reg D private placement investment.

These customer-initiated arbitration claims have not been resolved.

Background

A Reg D private placement is an unregistered securities offering sold to accredited investors under an exemption from the registration requirements of the Securities Act of 1933. Real estate-focused Reg D offerings often take the form of a Delaware Statutory Trust (DST), a vehicle commonly used by sponsors to package fractional interests in commercial real estate. DSTs are marketed as “passive” 1031 exchange replacement properties, and investors routinely place six- and seven-figure sales proceeds into them. Because DST interests are illiquid, valuations are opaque, and recourse is heavily constrained by trust documents that strip many of the protections an ordinary partnership investor would have, these products carry concentrated risks that the suitability and best-interest rules are designed to police.

FINRA Rule 2111 / Regulation Best Interest: For recommendations before June 30, 2020, FINRA Rule 2111 required brokers to have a reasonable basis for believing a recommended transaction was suitable for the customer based on the customer’s investment profile. For recommendations on or after that date, Regulation Best Interest (17 C.F.R. § 240.15l-1) requires brokers to act in the customer’s best interest.

FINRA Rule 3110 (supervision): Member firms must establish and maintain supervisory systems reasonably designed to achieve compliance with applicable securities laws and regulations. When those systems fall short, the firm can be held liable alongside the individual representative.

FINRA Rule 2010: Misrepresentation and omission claims implicate this rule directly, which requires member firms and associated persons to observe high standards of commercial honor and just and equitable principles of trade. These same conduct standards underpin most retail investment fraud claims arising from unregistered offerings.

When a customer’s claim alleges a breach of fiduciary duty, the question becomes whether the broker stood in a relationship of trust with respect to the recommendation and, if so, whether the broker placed the customer’s interests ahead of his own.

FINRA Rule 12206 governs eligibility for FINRA arbitration claims. Investors considering a claim should consult with a securities arbitration attorney to evaluate whether their situation falls within the applicable timeframe.

Warning Signs

Investors who placed money into Reg D private placements or DST real estate securities should review their account records for these indicators of broker misconduct: a sales pitch that downplayed illiquidity, lock-up periods, or the absence of a secondary market; a concentration of retirement savings or 1031 sale proceeds in a single sponsor’s offerings; offering documents the broker never walked through with the customer; distributions paid out of investor capital rather than property cash flow; periodic statements with values that did not move despite obvious deterioration in the underlying asset; and pressure to act before a 1031 exchange identification window closed. If any of these patterns apply to your account, a free consultation with a securities law attorney can help you understand whether you have a potential claim for damages.

Steps to Take Right Now

Gather your account statements, trade confirmations, and any correspondence with your broker or firm, including emails, texts, and written materials about the investments.
Look up your broker on FINRA BrokerCheck at brokercheck.finra.org to review their full disclosure record.
Contact a securities arbitration attorney for a consultation to evaluate your options.

Rosenberger + Kawabata represents retail investors in FINRA arbitration proceedings involving unsuitable private placement recommendations. Contact Rosenberger + Kawabata online for a free and confidential consultation, or call (310) 894-6921.

Sources

The information in this post comes from FINRA’s public BrokerCheck database. You can view the full detailed report (CRD# 4884717) here.

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