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.

Steve R. Caudle
AWC/2010022881701

Caudle borrowed $55,000 from a customer at his member firm in order to purchase real estate without providing prior written notice to, or obtaining prior written approval from, his member firm. At the time Caudle borrowed the money, the firm’s written procedures prohibited borrowing money from customers under any circumstances. Caudle completed a firm questionnaire and falsely answered “no” to the question, “Have you, or any related person or entity, borrowed or loaned any money or securities from/to a client (including situations where the loan is still outstanding and occurred prior to the individual becoming a client)?”

Steve R. Caudle : Fined $5,000; Suspended 90 days

Tags: Borrowing