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.

Deborah Jean Nehmad
OS/2008012884501

In connection with the purchase of a variable annuity, Nehmad created a handwritten statement and affixed a photocopy of a customer’s signature to make it appear that the customer had signed the statement acknowledging the percentage penalties she would incur for early withdrawals. Nehmad presented the statement to her member firm, falsely representing it to be a genuine copy of a document the customer had signed. 

Deborah Jean Nehmad: Fined $5,000; Suspended 1 year