Sarian impersonated customers via telephone in order to effect transactions in their accounts. He signed a relative’s name on a brokerage account withdrawal form to effect a transaction in the account.

Lenhardt directed an associate to use personal information of some of Lenhardt’s customers to establish online access to their accounts at another firm, and through that access, obtain value and performance information relating to whole life insurance policies that the customers held at that firm. Although the purpose for obtaining the information was to include it in personalized financial reports that were prepared for the customers, the access to their accounts and insurance policy information was obtained without the customers’ knowledge or consent.

Tieger  convinced his junior partner to call an annuity company and impersonate his relative for the purpose of confirming a $275,000 withdrawal from one of the relative’s variable annuity contracts.

The relative attempted to make a distribution from his variable annuity and after growing frustrated with the withdrawal process, instructed Tieger to take care of it. After multiple requests, Tieger’s junior partner agreed to make the telephone call using the relative’s cellular phone, spoke to the annuity company representative and, pretending to be Tieger’s relative, asked the representative to process the contract withdrawal. The junior partner answered the representative’s questions by reading from a script that Tieger had prepared.  Tieger watched the junior partner’s call from outside a glass conference room.

After Tieger left the office building, the junior partner called the representative back to inform him that he was not the relative and that he had called because someone standing next to him asked him to impersonate the relative.

Sternecker attempted to determine a customer’s total amount of investments without the customer’s knowledge or consent. Sternecker called a representative at another investment firm and inquired about the customer’s investments at that firm. Sternecker requested a firm office assistant to impersonate the customer and authorize the representative at the other firm to provide Sternecker with information about the customer over the phone. As part of the impersonation, the office assistant answered security questions about the customer from information the customer provided to Sternecker earlier; the security answers provided by the office assistant induced the other firm’s representative to provide Sternecker with the customer’s investment information.

The office assistant reported the impersonation to her manager, which led to an internal investigation and after Sternecker admitted to his misconduct, the firm terminated him.

As President of his member firm, White permitted the creation and dissemination of misleading sales and advertising materials to various state securities regulators in an effort to draw scrutiny to a business established by former registered representatives who left the firm to start their own business selling oil and gas interests. White made it appear as if the documents had been generated by an entity the former registered representatives established. A firm employee drafted and assembled the mailings to create the appearance that an officer or employee of the former registered representatives’ new business had generated and authorized the mailings. The mailings contained a cover letter drafted to draw regulators’ interest to the former registered representatives’ entity.

The mailings appeared to be from the former registered representatives’ entity, listed the name of an officer or employee of the entity, contained a return address of the entity on the envelopes used in the mailings, included printouts from the entity’s website, provided an executive memorandum, and also provided a “Confidential Private Placement Memorandum” and “Subscription Agreement” which both listed the former registered representatives’ new business throughout the documentation.