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.

Ward Byron Anderson
AWC/2008013164901

Anderson misappropriated money from public customers’ pension plans. This is an interesting scheme, so let me set it out in order and some detail:

For starters: 

Anderson’s company was a third-party administrator for a number of pension plans.

And now the fun begins:

Nastiness #1

1. Anderson received monthly checks from one customer and deposited the funds into his company’s account;
2. However, Anderson failed to forward the funds to the company in which the customer’s pension plan was invested;
3. INSTEAD, Anderson used the funds, which totaled to $222,700, for his own benefit. 

Nastiness #2

4. Anderson removed $250,000 from another customer’s pension plan by using signed blank withdrawal/transfer forms to cover up the $222,700 he had misappropriated from his other customer and used the remaining funds for his own benefit;
5. Following the withdrawal, Anderson created and provided to the second customer falsified statements containing information that would have applied if the $250,000 had not been withdrawn;
6. Then, Anderson used the remaining blank forms to further withdraw funds totaling $62,288 from the customer’s account for his own benefit;
7. Because of the falsified statements, Anderson was able to prevent the customer from discovering the misappropriation in excess of $312,000 for about 14 years. 

Big Surprise!

In addition, Anderson failed to respond to a FINRA request for information and documents and to appear for an on-the-record interview.

Ward Byron Anderson: Barred