Talk about the kitchen sink: OBA, PST, Undisclosed settlement, and unauthorized purchase. Frankly, the sanction struck me as a bit generous --- Frick either had a good lawyer or got to FINRA on a good day.

If I have one quibble, it's that I don't think FINRA is on particularly sound ground if it cites an RR for the undisclosed settlement of a complaint if there isn't an actual complaint but merely a "potential" complaint (there we go again with those troublesome adjectives and adverbs). All customers have potential complaints about virtually everything. Likely, Frick "anticipated" that the customer would complain about the misplaced money order, but that's not the same thing as charging her with the undisclosed settlement of an actual complaint. What happened here is that a money order (apparently for $1,100) was lost and rather than ask the customer to provide a replacement, Frick simply went out of her own pocket to cover the funds. No...that doesn't make her actions right but it does put them in a far different light than describing the underlying conduct as settling a customer complaint. We need to be particularly precise when drafting regulatory opinions because they are often used to support sanctions to be imposed in other similar cases.