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.

Joanne Lynn Cramer (Principal)
AWC/2009020729101

Cramer conducted transactions on behalf of the firm and its parent company after these entities terminated her as an employee and officer. After receiving the termination notice, Cramer sent a fax on firm letterhead instructing the firm’s bank to transfer $3,075 from the firm’s account to the firm’s parent company’s operating account. The bank processed the transaction as a journal entry according to Cramer’s instructions. Cramer sent the fax and signed it as president of the firm and its parent company although she never held the office of president of either the firm or its parent company. The journal entry was necessary to cover a $4,000 check payable to Cramer from the parent company’s operating account, which she wrote and presented for payment.

At the time of Cramer’s termination, she was in possession of another check payable to her in the amount of $65,679.88 written against the account of the parent company’s defined-benefit plan; this check was dated for a certain date before her termination, but Cramer did not present it for payment until a few days after her termination. Cramer sent an email to a representative of the firm’s clearing firm requesting that an inactivity fee be reversed; Cramer closed the email with her name, the firm’s name/the firm’s parent company’s name, and made no reference to the fact that she no longer had a position with either the firm or its parent company.

Joanne Lynn Cramer (Principal): Fined $5,000; Suspended 1 month in all capacities; Suspended 6 months in FINOP only capacities

Tags: FINOP