Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2009
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.
Patrick Vern Clarkson
AWC/2007008391201

Clarkson 

  • submitted variable life insurance applications for customers to his member firm, signing customers’ names on various documents without the customers’ knowledge, authorization or consent; and
  • created checks purporting to be from the customers (or purchased money orders with his own funds, signing the customers’ names to the money orders) and submitted them with the insurance applications to his member firm without the customers’ knowledge, authorization or consent. 

By engaging in this conduct, Clarkson received $41,667.98 in commissions from his firm, which subsequently reversed the commissions. 

Patrick Vern Clarkson: Barred
Bill Singer's Comment
Another good in-house catch!  Just shows you that firms can stay on the ball without being threatened all the time by heavy-handed regulators. Fact is, this is how things work best.  Diligent in-house compliance staffs looking for trouble, finding it, and pouncing on it. Unfortunately, as we all know, you still need an outside, strong regulatory oversight  for those situations in which the temptation of money outweighs the desire to do things right.  Still -- if there were more of these scenaria then Wall Street would have far less trouble.
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