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.

Nicole R. Palumbo
AWC/2010023810201

Palumbo activated ATM cards, linked them to bank customer accounts and affected unauthorized ATM withdrawals from the customers’ accounts, which totaled approximately $36,895.

Palumbo did not have permission or authority from the customers or the bank to link the ATM cards to the customers’ accounts or withdraw funds from the accounts. Palumbo effected a $1,000 direct cash withdrawal from another customer’s account without permission or authority from the customer or bank. These transactions did not involve funds from an account held at a FINRA-regulated entity.

Nicole R. Palumbo: Barred

Tags: ATM