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.
December 2009 - View all for this month
Judy Jo Patrick
AWC/2008013438901
Patrick altered public customers’ Withholding Certificate for Pension or Annuity Payment Forms (IRS Form W-4P) by affixing invalid copies of the customers’ signatures. Patrick similarly altered her member firm’s internal documents regarding public customers, thereby causing the firm’s books and records to be inaccurate and not in compliance with Section 17(a) of the Securities Exchange Act of1934 and SEC Rule 17a-3. Patrick failed to respond to FINRA requests for information.
Judy Jo Patrick: Barred
Tags: Forgery  
Bill Singer's Comment
As I've noted so often over the years, I am not a fan of regulatory double-speak -- which is that twisting of English into something that is bloated and obtuse but always sounds oh so precise.  For example, is it just me or what but doesn't this strike you as a classic:

[P]atrick altered public customers’ Withholding Certificate for Pension or Annuity Payment Forms (IRS Form W-4P) by affixing invalid copies of the customers’ signatures . . .

Apparently, all that this registered person did was "altered" an IRS form by "affixing invalid copies" of signatures.  Altered? Affixing?  Whatever happened to the old-fashioned  "fraud" or "forgery"? 

When I think of "altering" something, it means that I take something that exists and shorten/lenghten it.  For example, you alter a hemline. However, you are not altering someone's signature when you forge it or when you submit a prior iteration of that signature as if it were new and authorized.  That may be fraud or forgery but it sure as hell isn't a mere alteration -- nor is it simply affixing an invalid copy. 

I mean, seriously, if I make a copy of the Mona Lisa and sneak into the Louvre and remove the original and replace it with my forgery, would anyone suggest that all that I had done was altered the original and affixed an invalid copy onto the museum wall?
Enforcement Actions
Search in Cases of Note : FINRA
Months
 
Cases of Note : FINRA Archive
Tags