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.

Jill A. Kleinerman
AWC/2007008322701

In order to obtain authorization for withdrawals totaling $37,299.55 for a public customer directly from her IRA securities account, Kleinerman completed a distribution request form, dated the form in her own handwriting, affixed a photocopy of the customer’s signature onto the form and submitted it to her member firm. Kleinerman used a photocopy of the customer’s signature several times on distribution request forms with the customer’s full knowledge or consent. 

Jill A. Kleinerman: Fined $2,500 in light of her financial status; Suspended 30 days