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.

Kristen Anne Jacques
AWC/2010024077701/November 2011

Associated Person created expense reports associated with personal expenses charged to her member firm-issued credit card, which she ultimately paid. Each expense report, Jacques labeled each expense as “personal” and attached a check to reimburse the firm for the personal expenses charged. Jacques signed her supervisor’s signature on a line on each expense report titled “authorized approval signature,” and stamped her supervisor’s printed name on a line with the instruction “print approver name.”Jacques submitted the expense reports to the firm; neither the firm nor Jacques’ supervisor gave her permission or authority to add her supervisor’s signature to the expense reports.

Kristen Anne Jacques: Censured; Fined $5,000; Suspended 1 year

Tags:  Expenses     |    In: Cases of Note : FINRA

Tracey McInchak
AWC/2010022690601/November 2011

Associated Person McInchak wrote numerous checks, totaling $461,013.14, from her member firm’s corporate checking account made payable to herself and to her personal credit card companies. McInchak cashed the checks and used them for her own benefit without the firm’s knowledge or permission.

Tracey McInchak: Barred

Tags:  Checks    Credit Cards    Expenses     |    In: Cases of Note : FINRA

David Do-Yong Lee
AWC/2010023019701/October 2011

Lee misappropriated $900 from his member firm by claiming and receiving reimbursement for personal expenses, which he claimed as business expenses, thus converting his firm’s funds to his own use. Lee caused his firm’s books and records to be inaccurate.

David Do-Yong Lee: Barred

Tags:  Expenses     |    In: Cases of Note : FINRA

Jaime Campos Lopez
AWC/2009018640401/October 2011

After discussing with his member firm the possibility of him participating as an exhibitor during a dental convention by representing the firm at a booth in the exhibition hall and distributing literature, Lopez did not follow up and formally request permission, contrary to the firm’s written procedures. Despite the lack of the firm’s approval, Lopez arranged for and participated as an exhibitor representing the firm by staffing an exhibition booth at the convention and distributed, or had available for distribution, literature about the firm and himself. 

Lopez provided FINRA with inaccurate and misleading information.

Jaime Campos Lopez : Fined $5,000; Suspended 2 years

Tags:  Expenses     |    In: Cases of Note : FINRA

Kimberlie Munsie Clark (Principal)
AWC/2010025003701/July 2011

Clark was her firm’s Chief Financial Officer and co-Chief Operating Officer with authority to write checks from its checking accounts, including checks for her own compensation, and she misappropriated $8,333.33 from her member firm. Clark was entitled to a payroll check in the amount of $8,333.33 and issued a check to herself for that amount and, without the firm’s permission, issued herself another $8,333.33 check. Both payroll checks were deposited in Clark’s personal banking account.

Kimberlie Munsie Clark (Principal): Barred

Tags:  Checks    Expenses     |    In: Cases of Note : FINRA

Michael Paul Dickamore
2009017212301/May 2011

Dickamore used his member firm’s corporate credit card for personal expenses in the amount of $50,413.56 without the firm’s permission or authority, and submitted the charges as business expenses for the firm reimburse. During an interview with his firm, Dickamore admitted that he purchased personal items with his corporate credit card and falsely identified those items as business expenses. Dickamore reimbursed the firm in full. but failed to respond to FINRA requests for information and failed to appear for on-the-record testimony.

Michael Paul Dickamore : Barred

Tags:  Expenses    Corporate Credit Card     |    In: Cases of Note : FINRA

Christopher Malchin
AWC/2010021389601/April 2011

Malchin utilized his business credit card for personal expenses and submitted false expense reports to his member firm, pursuant to which he was reimbursed approximately $1,806 for expenses that were not business-related.

Christopher Malchin : Fined $5,000; Suspended 6 months

Tags:  Credit Cards    Expenses     |    In: Cases of Note : FINRA

DaLean Annette Rials (Supervisor)
AWC/2009019405601/April 2011

Rials misappropriated approximated $70,000 from her member firm. Rials, as operations manager of her firm’s branch office, had authority to approve credits to customer accounts up to a specified dollar amount without additional approval. Rials used this authority to credit reimbursements totaling approximately $50,000 for non-existent fees and expenses in accounts belonging to her friends and family. Rials then withdrew the credited amounts from family accounts or received cash or checks from friends for the credited amounts.

Rials submitted expense reports for approximately $20,000 in personal expenses, falsely identifying them as legitimate business expenses. Rials improperly accessed her supervisor’s computer and approved some of her own expenses reports.

DaLean Annette Rials (Supervisor): Barred

Tags:  Expenses    Computers     |    In: Cases of Note : FINRA