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.

David Michael Pagliarulo
AWC/2009017267701

Pagliarulo signed customers’ names on a variety of internal and external documents related to their accounts that he serviced. Pagliarulo also copied, cut and pasted another customer’s name on the firm’s explanation of transaction form. All of the customers authorized Pagliarulo’s action in each instance, but only one of the customers authorized him to sign their name on the respective documents. Pagliarulo knew that the firm did not permit employees to sign customers’ names on documentation related to their accounts.

David Michael Pagliarulo : Fined $10,000; Suspended 2 years

Tags: Signature