Securities Industry Commentator by Bill Singer Esq

Unhappy Customers Pull Out All the GameStops In FINRA Arbitration Win Against Charles Schwab (BrokeAndBroker.com Blog)

What Happens in The Metaverse Does Not Stay In The Metaverse Texas Securities Commissioner Stops Metaverse Casino Securities Scheme (TSSB Release)

New York Man Pleads Guilty for His Role in a Computer Fraud Scheme that Targeted the Elderly (DOJ Release)

Montgomery County and Florida Women Convicted of Conspiring to Access Company Computers For Money (DOJ Release)

DC Solar CFO Sentenced to 6 Years in Prison for Billion Dollar Ponzi Scheme (DOJ Release)

SEC Charges Shareholders, Attorney in Penny Stock Fraud Scheme (SEC Release)

Statement in the Matter of David Hansen by SEC Commissioner Hester M. Peirce

"Building Upon a Long Tradition" - Remarks before the Ceres Investor Briefing by SEC Chair Gary Gensler

FINRA Fines and Suspends Morgan Stanley Rep Over Joint Production Credits With Retired Rep's Estate

In the Matter of William Martin Beasley, Respondent (FINRA AWC)

For a Second Time, Federal Court Says Price Isn't Right In UBS Whistleblower Retaliation (BrokeAndBroker.com Blog)

Former Morgan Stanley Rep Should Count His FINRA Settlement Blessings (BrokeAndBroker.com Blog)

1. This Emergency Cease and Desist Order is being entered to stop an illegal and fraudulent securities scheme tied to virtual casinos - including virtual casinos in metaverses. 

2. Metaverses are virtual worlds focused on social connections, interactivity, commerce, entertainment and business. Various concepts of a singular metaverse or many different metaverses incorporate blockchain and web 3.0 technologies, access points such as computers and AR or VR headsets, the interoperability of digital assets and the use of non-fungible tokens or NFTs. 

3. In this case, the parties are representing they are developing an internet casino and virtual casinos in various metaverses. Customers, acting virtually through avatars, will purportedly visit the metaverse casinos, particulate in weekly tournaments, gamble on virtual horse racing and play virtual games such as blackjack, poker and baccarat. 

4. The parties are funding the internet and metaverse casinos through the sale of more than 12,000 NFTs to the public. 

5. The NFTs entitle owners to various benefits, including a pro rata share of profits generated by the internet and metaverse casinos. Respondents are estimating these profits may be worth as much as $6,750 per month or $81,000 per year. 

6. Although the NFTs constitute securities, Respondents are advising purchasers that securities laws do not currently regulate NFTs and are considering further steps to obstruct the regulation of their NFTs. 

7. The advice regarding regulation is simply not true and the offering of NFTs is a high-tech scam. The parties are concealing their locations, hiding the identities of managers, misleading potential purchasers about their experience and obscuring the significant risks associated with investing in their NFTs. 

8. The Securities Commissioner is entering this Emergency Cease and Desist Order to stop the scheme and prevent immediate and irreparable harm to the public.

[I]n December of 2016, Alam became involved in a computer technical support fraud scheme that targeted elderly victims throughout the United States including the Middle District of Louisiana.  The scheme involved international participants, targeted over 30 victims, and took in approximately $340,000 in fraudulent proceeds.

Members of the scheme tricked victims into thinking their computers needed technical support, then offered to fix their computers for a fee.  After the victims paid, a member of scheme would contact the victims seeking access to their bank accounts, claiming that the victims were entitled to a discount.  With that information, a member of the scheme would manipulate the victims' account balances to where the victims thought that they owed money to the computer company.  The victims would then send money to accounts controlled by Alam and others.

Between December of 2016 and March of 2018, Alam utilized multiple bank accounts to receive the victims' funds.  He operated these accounts at the direction of an overseas associate, who instructed him how to distribute the funds, which he then sent to foreign and domestic accounts as directed.

In September 2019, the defendants were charged with one count of conspiracy, three counts of unauthorized access to a computer, and aiding and abetting, stemming from their scheme to receive a payment of money from the Prostate Cancer Foundation (PCF), Denis' former employer. In support of that scheme, they accessed internal documents obtained via unauthorized access to the computer system of PCF and threatened to release them to the public. Denis was hired by PCF in August 2014 but left her position shortly thereafter.

Evidence presented at trial showed that on several occasions over the course of several days after Denis left her employment, PCF computers were accessed, and documents were downloaded to her laptop and emailed to Eddings. In a series of emails sent by Eddings to PCF, the defendants demanded a payment of $150,000 in lost wages for Denis, as well as a $37,500 payment for Eddings for acting on Denis' behalf. In those emails, Eddings threatened to release the documents to the public if their demands were not met. When their demands were ultimately not met, Eddings sent a series of emails to the PCF Board, PCF donors, and members of the media, sharing her previous correspondence and attaching the documents.

[K]armann was a certified public accountant (CPA) that DC Solar hired first as its Controller in 2014, and later as its Chief Financial Officer. DC Solar manufactured mobile solar generator units (MSG), which were solar generators that were mounted on trailers. The MSGs were sold to investors who were given generous federal tax credits, and who were falsely led to believe that there was extensive demand from third parties to lease these MSGs to create a revenue stream. In fact, that demand was virtually non-existent. DC Solar had instead become a fraud scheme that took new investor money to pay older investors, using circular transactions that were fraudulently disguised to look like real third-party lease revenue.

According to court documents, Karmann and the other co-conspirators, including company founder Jeff Carpoff, carried out an accounting and lease revenue fraud using the Ponzi-like circular payments. Carpoff and others lied to investors about the market demand for DC Solar's MSGs and its revenue from leasing to third parties. Then Karmann, Carpoff, and others covered up these lies with techniques including false financial statements, false operation reports, and false written summaries of the supposed revenue from leasing MSGs to third parties. In 2016, 2017, and 2018, Karmann oversaw the hidden circular transfers of funds, delivered false financial information to another co-conspirator for use in tax returns and tax documents, provided false compiled financial statements to an investor representative for multiple funds, and provided other false information to investor representatives about DC Solar's third-party leasing. Karmann also directed others in DC Solar's accounting department, including one subordinate whom Karmann told to "make it up" when responding to a customer request for location reports on their MSGs. During these years that Karmann knowingly joined in the fraud, DC Solar pulled in over $600 million in investor funds as a result of this scheme.

On Nov. 9, 2021, Jeff Carpoff was sentenced to 30 years in prison and ordered to pay $790.6 million in restitution for conspiracy to commit wire fraud and money laundering. His wife, Paulette Carpoff, 47, has pleaded guilty to conspiracy to commit an offense against the United States and money laundering, and is scheduled to be sentenced on May 10, 2022.

On Nov. 16, 2021, Joseph W. Bayliss was sentenced to three years in prison and ordered to pay $481.3 million in restitution for securities fraud and conspiracy in connection with the DC Solar scheme.

Other defendants have pleaded guilty to criminal offenses related to the fraud scheme and are scheduled for sentencing: Alan Hansen, 50, of Vacaville, is scheduled to be sentenced on April 26, 2022; Ronald J. Roach, 54, of Walnut Creek, is scheduled to be sentenced on May 3, 2022; and Ryan Guidry, 44, of Pleasant Hill is scheduled to be sentenced on June 7, 2022.

[F]rom at least April 2017 through August 2017, the defendants each played a role in a scheme that enabled Herman and Island Capital to sell shares of penny stock issuer NxGen Brands, Inc. f/k/a Pyramidion Technology Group, Inc. ("PYTG") to unsuspecting investors. To create the appearance that PYTG had assets and business operations and was not merely a public shell company, Baker allegedly facilitated a sham acquisition by PYTG. For his part in the scheme, Horn allegedly provided PYTG's transfer agent with fraudulent Rule 144 opinion letters that enabled Herman and Island Capital to obtain unrestricted shares of PYTG. According to the complaint, Herman and Island Capital then engaged in manipulative trading to raise PYTG's share price and, with the assistance of paid boiler rooms, dumped their shares of PYTG at the inflated price, reaping profits of over $1 million, collectively.

Exchange Act Rule 21F-17(a), adopted in 2011 as part of the whistleblower program mandated by the Dodd-Frank Act, prohibits taking "any action to impede an individual from communicating directly with the Commission staff about a possible securities law violation, including enforcing, or threatening to enforce, a confidentiality agreement . . . with respect to such communications." The Commission's Order concludes that David Hansen, a co-founder of NS8, Inc. who held various positions in the company, including Chief Information Officer, violated Rule 21F-17(a). The alleged violation related to Mr. Hansen's response to concerns raised with him by an NS8 Employee that the company was overstating the number of paying customers. The Order does not explain what, precisely, Mr. Hansen did to hinder or obstruct[1] direct communication between the NS8 Employee and the Commission. Accordingly, I dissent from instituting the action and accepting the settlement.

The Order states that the NS8 Employee was concerned that "NS8 was overstating its number of paying customers, including that the customer data . . . used to formulate external communications-including to potential and existing investors-was false." After submitting a tip to the Commission, the NS8 Employee raised these concerns with Mr. Hansen and told Mr. Hansen "that unless NS8 addressed this inflated customer data, he would reveal his allegations to NS8's customers, investors, and any other interested parties." Mr. Hansen, who "understood that the . . . concerns involved a possible securities law violation," suggested to the NS8 employee that he raise his concerns to his supervisor or to NS8's CEO, and the employee conveyed his concerns to his supervisor later that same day. The supervisor then called Mr. Hansen, who then called NS8's CEO.

The Order has several sentences describing interactions between Mr. Hansen and the CEO and their subsequent actions, but the salient facts, as I see them,[2] are:

• The "CEO told Respondent that he [the CEO] removed NS8 Employee's administrator privileges to one system but kept read-only access 'so it looks like an error.'"
• Mr. Hansen told the CEO that the NS8 Employee's company-issued computer had a tool that permitted remote access, and that Mr. Hansen could " 'watch what [the NS8 Employee] is doing [on his company-issued computer] if we care.' "[3]
• Mr. Hansen "used NS8's administrative account to access the NS8 Employee's company computer" and "then left the NS8 Employee's computer and password in the CEO's office."
• The CEO fired the NS8 Employee later in the week.

Although the Order states that "both took steps to remove the NS8 Employee's access to NS8's IT systems," the above list includes only two concrete actions by Mr. Hansen: (1) accessing the NS8 Employee's computer and (2) leaving the computer and password in the CEO's office. How did Hansen's actions as set forth in the Order remove the NS8 Employee's access to the IT systems, let alone stand in the way of the NS8 Employee's direct communication with the Commission? In my view, they quite plainly did not.

At most, these actions affected the content of what the NS8 Employee could communicate, not whether he could communicate. Rule 21F-17(a) ensures the whistleblower's entitlement to speak directly to the Commission, and NS8 did not prevent the NS8 Employee from doing so. Actions that limit access to company data do not necessarily limit access to the Commission. Mr. Hansen's actions, as reported in the Order, did not hinder the NS8 Employee's communications with the Commission regarding his already-submitted tip.[4] Furthermore, the Order does not state that Mr. Hansen knew about the tip. If there were evidence that he knew of the tip, then his actions may have implicated Rule 21F-17(a) or the anti-retaliation rules.

A broad interpretation of Rule 21F-17(a) could prohibit companies from limiting employees' access to data. Limiting access to sensitive data is a common element in cybersecurity programs.[5] A plausible inference, based on the facts recited in the Order, is that Mr. Hansen was concerned about the NS8 Employee's threat to disclose confidential company data "to NS8's customers, investors, and any other interested parties." Rule 21F-17(a) by its plain terms applies only to communications with the Commission. We should not read it in a manner that complicates a company's ability to act to protect its data in the face of sweeping disclosure threats, even well-intentioned ones by concerned employees. Companies hold troves of data about their customers, assets, and business practices. They and their customers have a keen interest in protecting those data. We should not engage in an undisciplined interpretation and application of Rule 21F-17(a) that adds unnecessary legal risk to that burden.

I respectfully dissent.

= = = = =

[1] Impede means "to retard in progress or action by putting obstacles in the way; to obstruct; to hinder; to stand in the way of." Oxford English Dictionary (1971).

[2] The Order also states that the NS8 Employee used a password management system installed on his NS8-issued computer to save passwords both "to various NS8-related applications" and to "his personal email and other applications." Additionally, the Order states that the saved passwords were used to access his personal accounts "on his NS8-issued laptop" the same day Mr. Hansen left the computer in the CEO's office. Because the Order does not identify who accessed what personal accounts, the relevance of these facts is not clear.

[3] The Order does not state that Mr. Hansen (or anyone else) in fact watched.

[4] The Order states that it was the CEO who limited the NS8 Employee's "privileges to one system" to "read-only access" and later fired the NS8 Employee, and does not state that Mr. Hansen had any role in either action.

[5] See, e.g., Cybersecurity Risk Management for Investment Advisers, Registered Investment Companies, and Business Development Companies, Rel. No. 34-94197, https://www.sec.gov/rules/proposed/2022/33-11028.pdf (proposing rule § 275.206(4)-9(a)(2)(4) to require as "an element of an adviser's or fund's reasonably designed policies and procedures . . . [r]estricting access to specific adviser or fund information systems or components thereof and adviser or fund information residing therein solely to individuals requiring access to such systems and information as is necessary for them to perform their responsibilities and functions on behalf of the adviser or fund").

Thank you. It's good to be with Ceres for today's investor briefing. As is customary, I'd like to note that my views are my own, and I'm not speaking on behalf of the Commission or SEC staff.

As you all likely know by now, in March, the Commission voted on a proposal to mandate climate-risk disclosures by public companies.

A Long Tradition

Let me put the proposal into the context of our long tradition of disclosures.

The core bargain from the 1930s is that investors get to decide which risks to take, as long as public companies provide full and fair disclosure and are truthful in those disclosures.

Over the generations, the SEC has stepped in when there's significant need for the disclosure of information relevant to investors' decisions.

The first disclosures revolved around companies' financial performance, who runs the company, and how much of a company's resources were dedicated to paying those executives.

In addition to such historical information, though, investors want to assess potential risks. Risk, by its definition, often involves events that have not yet occurred.

In 1964, the SEC started to offer guidance about disclosure of risk factors. The agency later adopted disclosure requirements related to Management's Discussion and Analysis in Form 10-K. The existing environmental-related disclosure requirements date back to the 1970s. The Commission elaborated on these requirements repeatedly in subsequent decades. This includes the SEC's guidance from 2010 regarding climate-related disclosures.

Across all of these disclosures, the same principles apply: Again, investors get to decide which risks to take, as long as public companies provide full and fair disclosure and are truthful in those disclosures.

Further, the SEC has a role to play in terms of bringing some standardization to the conversation happening between issuers and investors, particularly when it comes to disclosures that are material to investors.

In making decisions about disclosure requirements under the federal securities laws-including decisions about the proposed climate-related disclosures-I am guided by our three-part mission: to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. I also am guided by the concept of materiality. As the Supreme Court has explained, information is material if "there is a substantial likelihood that a reasonable shareholder would consider it important" in making an investment or voting decision, or if it would have "significantly altered the total mix of information made available."[1] Forward-looking statements, such as forecasts and risks, also can be material, as standards by both the Supreme Court[2] and the Commission[3] have articulated.

I believe the proposed rule would build on that long tradition. It would provide investors with consistent, comparable, and decision-useful information for their investment decisions and would provide consistent and clear reporting obligations for issuers.

Today's Practices

And here's the thing. Climates disclosures are already happening.

Today, investors are already making investment and voting decisions using information about climate risk.

Today, hundreds of companies are already disclosing this information. That conversation is already going on. Many of the existing disclosures build upon the Task Force on Climate-related Financial Disclosures (TCFD) and the Greenhouse Gas Protocol.

The TCFD was formed in 2017, reporting to the Financial Stability Board of the Group of Twenty (G20). The task force comprises 30-plus market folks (not government officials) who came together to create a climate disclosure reporting framework.[4]

Five years later, this TCFD framework has been used by thousands of companies across the globe as the basis for reporting climate-risk information. Beyond that, many countries already have started to develop reporting regimes that build on or incorporate the TCFD framework, too, including Brazil, the European Union, Hong Kong, Japan, New Zealand, Singapore, Switzerland, and the United Kingdom.

One report found that 70 percent of companies in the Russell 1000 Index published sustainability reports in 2020 using various third-party standards, which include information about climate risks.[5] SEC staff, in reviewing nearly 7,000 annual reports submitted in 2019 and 2020, found that a third included some disclosure related to climate change.

Today, investors representing literally tens of trillions of dollars support climate-related disclosures because they recognize that climate risks can pose significant financial risks to companies, and investors need reliable information about climate risks to make informed investment decisions. For example, investors with $130 trillion in assets under management have requested that companies disclose their climate risks.[6] That information could influence shareholders' evaluations, risk management, or investment decisions to buy or sell a security and how to vote on a merger or other proxy vote.

Companies and investors alike would benefit from the clear rules of the road in the release, particularly as those rules reflect what is becoming widely accepted across the globe.

It makes sense to build on what so many companies are already doing to enhance the consistency, comparability, and decision-usefulness of these disclosures for investors.

Proposal Building upon the Traditions

The proposal thus draws on the SEC's long tradition and what is currently happening in this arena.

Filed

These disclosures would be filed in the 10-K, rather than solely on a company website or elsewhere. Why? Investors look for relevant information in filings like the 10-K when assessing an investment decision. That was true when I was on Wall Street. It's true of the MD&A sections; it's true of the risk factors; it's true of the environmental disclosures starting in the 1970s. It's true for other key disclosures today.

It is important that investors be able to find consistent, comparable, and decision-useful information in one place rather than having to piece together information from different locations that might, in turn, differ from one issuer to another.

Further, placing disclosures in filings also benefits investors because there are more controls around those disclosures, with a framework required from Section 302 of the Sarbanes-Oxley Act of 2002.

There are some costs to this, but on balance, I believe this consistency, along with the enhanced control environment, brings greater benefits and efficiencies to these disclosures.

A few days after the SEC's proposal came out, the International Sustainability Standards Board (ISSB) made its own proposal on global climate-related disclosure requirements.[7] It, too, proposes climate disclosures as a part of general purpose financial reporting, among other similarities with the SEC proposal.

Disclosures-Strategy, Governance, Risk Management, and Targets

I'd like to touch on the main components of the proposal.

The first is bringing consistency and comparability to how a management team discloses a company's strategy, governance, and risk management with respect to climate-related risks, building upon the TCFD framework.

The second is disclosure for companies that set targets or use internally developed target plans, transition plans, scenario analyses, or carbon pricing as part of their risk management process.

If you, the reporting company, have a target, under the proposal you would need to disclose your plans to get to that target. If you have a transition plan, you would need to provide disclosure about that plan. If you employ scenario analysis or use internal carbon pricing as part of your risk management, then you would disclose those too. It's up to a company to determine whether to have a target, transition plan, scenario analysis, or carbon pricing. If a company chose not to make those statements or use those tools, no disclosure would be required. The decision on whether to make these statements or use these tools, though, remains entirely up to you as the company.

To the extent that the proposed disclosures would include some forward-looking statements, such as projections of future risks or plans related to targets or transitions, the forward-looking statement safe harbors pursuant to the Private Securities Litigation Reform Act would apply, assuming certain conditions were met.

We have a disclosure-based regime, not a merit-based one.

Thus, the design of the proposal is consistent with those long traditions and the law; with concepts of investor decision-making and related materiality; and with what companies are already doing based on the TCFD and GHG Protocol frameworks.

Disclosures-Financial Statement Metrics

The proposed rules also would require a company to disclose "certain disaggregated climate-related financial statement metrics that are mainly derived from existing financial statement line items" in a note to its financial statements. This would include the impact of the climate-related events and transition activities on the company's consolidated financial statements.

Disclosures-Greenhouse Gas Emissions

In addition, the proposal addresses disclosure of greenhouse gas emissions. Greenhouse gas emissions data are increasingly being used as a quantitative metric to assess a company's exposure to-and the potential financial effects of-climate-related transition risks. Those risks could include regulatory, technological, and market risks driven by a transition to a lower greenhouse gas emissions economy, with potential financial impacts on revenues, expenditures, and capital outlays.

All filers would disclose their Scope 1 and Scope 2 greenhouse gas emissions-emissions that "result directly or indirectly from facilities owned or activities controlled by a registrant." Thus, these data should be reasonably available to issuers.

Under the proposed rules, some registrants also would be required to disclose Scope 3 emissions-the emissions from upstream and downstream activities in a company's value chain-if such emissions were material or if the company had made a commitment that referred to Scope 3 emissions.

So if you've made a commitment, or if the information is material, it makes sense to measure and report it.

The Commission proposed different requirements for Scopes 1 and 2 as opposed to Scope 3, as methodologies for determining Scope 3 emissions currently aren't as well developed as the others are just yet.

The proposal would phase in Scope 3 disclosures after Scopes 1 and 2; a new liability safe harbor would be available for Scope 3 disclosures; and smaller reporting companies would be exempt from Scope 3 disclosures.

Feedback from the Public

Since the proposal has been released, we've already gotten a lot of feedback. Some are for the proposal, some against. That's what we need to hear, and we need to hear the reasons, too. We need to hear all sides of this. We consider all of those comments in determining whether and how to adjust the release as we move forward.

We look forward to and will benefit from your public comment on all the key areas of the proposal, including but not limited to how it approaches disclosure regarding strategy, governance, risk management, targets, financial statement metrics, and greenhouse gas emissions.

I know some aspects of the proposal might interest certain commenters more than others, but I'll be clear: We are seeking feedback on every line item, and we benefit from all of those comments.

It would be good to hear from issuers and investors of all sizes, from all corners of the U.S. and segments of the marketplace. That includes those who are involved in conversations between issuers and investors, like investor relations departments, chief executive officers, and chief financial officers. What are investors asking of you? How do you and your competitors decide what disclosures to make? What would help bring greater consistency, comparability, and decision-usefulness for investors' decisions? What are the economics here?

We encourage a wide range of investors, from individual to institutional, to weigh in. What helps you and facilitates your making decisions? Which components of this proposal work? What needs adjustment? How are you using the disclosures that you're already getting today?

That begs the question: How do you comment? Go to www.sec.gov. Under the Regulation menu, click on Proposed Rulemaking, scroll down to the proposal on March 21, 2022. There, you can find the release[8] and the comments form.[9] I'll also link to the form in the footnotes of this speech on sec.gov as well.

Thank you, and I look forward to your questions-and your feedback.

[1] Basic Inc. v. Levinson, 485 U.S. 224, 231-32 (1988) (quotation marks omitted).

[2] Id. at 238-39.

[3] See, e.g., 17 CFR 229.303(a); Release No. 33-10890, Management's Discussion and Analysis, Selected Financial Data, and Supplementary Financial Information (Nov. 19, 2020), [86 FR 2080, 2089 (Jan. 11, 2021)].

[4] See "Task Force Members" (as of April 11, 2022), available at https://www.fsb-tcfd.org/members/.

[5] See Governance & Accountability Institute, Sustainability Reporting in Focus, 2021, available at https://www.gainstitute.com/fileadmin/ga_institute/images/FlashReports/2021/Russell-1000/G_A-Russell-Report-2021-Final.pdf?vgo_ee=NK5m02JiOOHgDiUUST7fBRwUnRnlmwiuCIJkd9A7F3A%3D.

[6] See CDP, Request Environmental Information, available at https://www.cdp.net/en/investor/request-environmental-information#d52d69887a88f63e15931b5db2cbe80d.

[7] See "ISSB delivers proposals that create comprehensive global baseline of sustainability disclosures" (March 31, 2022), available at https://www.ifrs.org/news-and-events/news/2022/03/issb-delivers-proposals-that-create-comprehensive-global-baseline-of-sustainability-disclosures/.

[8] See The Enhancement and Standardization of Climate-Related Disclosures for Investors, Release No. 34-94478 (Mar. 21, 2022) [87 FR 21334 (Apr. 11, 2022)], available at https://www.sec.gov/rules/proposed/2022/33-11042.pdf.

[9] See SEC, "How to Submit Comments," available at https://www.sec.gov/cgi-bin/ruling-comments.

In approximately January 2016, Beasley entered into an agreement through which he agreed to service certain customer accounts, including executing trades for those accounts, under a joint representative code (also known as a joint production number) that he shared with the estate of a retired representative. The agreement set forth what percentages of the commissions Beasley and the retired representative's estate would earn on trades placed using the joint representative code. 

From January 2016 through December 2020, Beasley placed a total of 114 trades in accounts that were covered by the agreement using his own personal representative code. Specifically, although the firm's system correctly prepopulated the trades with the applicable joint representative code, Beasley negligently entered the 114 transactions at issue under his personal representative code. The firm's trade confirmations for the 114 trades inaccurately reflected Beasley's personal representative code instead of the joint representative code that Beasley shared with the estate of a retired representative. 

Beasley's actions resulted in his receiving higher commissions from the 114 trades than what he was entitled to receive pursuant to the agreement. In September 2021, Morgan Stanley reimbursed the estate of the retired representative.  

• Securities Industry Commentator
• Bill Singer