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.

NAME REDACTED (Supervisor)
AWC/2008014144201

REDACTED submitted requests to her member firm to make charitable sponsorship payments to a non-profit organization that she served as a vice president and a member of the board of directors, which was disclosed in writing to, and approved by, her firm. The firm approved REDACTED’s requests and made the sponsorship payments through checks.

The founder and executive director of the non-profit wrote checks totaling $20,275 to himself from the non-profit’s account at REDACTED’s firm. REDACTED communicated with the founder about his personal use of the funds in a series of emails through her firm email account, which show that the founder used the funds for a move to a new place of residence, for rent and utilities and for cell phone bills, among other expenses; in one of his emails to REDACTED, the founder promised to pay the funds back.

In an email to the founder, REDACTED told him to use the money from the non-profit’s account to help him get established at his new place of residence and that they would find a way to build the funds back up over time. Thereafter, REDACTED submitted the final request for a sponsorship payment of $5,000 to be made to the non-profit.

In addition, REDACTED was in possession of a checkbook belonging to the non-profit and, per the founder’s oral authorization, REDACTED wrote checks and improperly signed the founder’s name to those checks, but REDACTED did not have written authorization to sign the checks and did not place any notation on the checks indicating that she was signing the checks on the founder’s behalf. The checks totaled approximately $7,723 and were made payable either to third parties or to “cash”; of this total, approximately $3,415 was paid through checks written to “cash,” thereby REDACTED improperly signed the name of an authorized signatory of a customer account on checks.

REDACTED failed to timely comply with a FINRA request that she provide testimony in connection with a FINRA investigation.

NAME REDACTED (Supervisor): Fined $10,000; Suspended 2 years

Tags: Checks  Signature