Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2010
NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.
November 2010 - View all for this month
Maria Alicia Wild
AWC/2010021987401
Wild obtained a bank form a customer signed authorizing payment of the customer’s credit card bill in the amount of approximately $13,280, but after she had obtained the signed authorization form, the amount of the bill had increased by approximately $190. Wild cut the customer’s signature from the signed authorization form that authorized payment of the bill in the amount of approximately $13,280 and pasted the signature to another bank form that authorized payment of the bill in the amount of approximately $13,470, without the customer’s prior knowledge, consent or authorization.
Maria Alicia Wild: Fined $5,000; Suspended 1 month
Tags: Credit Cards  
Bill Singer's Comment

Okay -- maybe I'm missing something here.  Lemme see if I have this right.

1. Client owes a $13,280 credit card bill.

2. Wild gets signed authorization from client to pay that $13,280 bill.

3. Between hence and thence, the balance due increase by $190 to $13,470.

4. Rather than "bother" the client and resubmit the paperwork for her signature, Wild foolishly cuts and pastes the client's old signature onto a new authorization to pay the $13,470 revised bill.

Assuming that I got it all correct -- and assuming that you note that I described Wild as "foolishly" engaging in the self-help measures with the second form -- I'm not sure that this all adds up to both a $5,000 fine AND a one month suspension.  I'm am in no way excusing the "forging" of the signature or the potentially dangerous acts of failing to get a customer's prior authorization. We all clear about that?  However, it doesn't strike me that Wild's motivation was venal and I'm not sure why, say, a $500 fine would not have sent the appropriate message based upon the facts at hand.  If you wanted to toss in a 5 day suspension on top of that, go ahead.  However, regardless of FINRA's perspective, $5,000 is a lot of bucks.

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