Puplava’s non-registered assistant had access to his signature guarantee stamp, and without Puplava’s knowledge, permitted the member firm’s registered representatives to use the signature guarantee stamp to approve securities business-related transactions and paperwork that required a signature guarantee stamp. Puplava discovered this practice and instructed his non-registered assistant and the registered representatives involved to discontinue the practice, but Puplava did not take back his signature guarantee stamp or take steps to otherwise secure the stamp to prevent its misuse. Puplava had customers sign blank securities business-related forms, including non-brokerage change request forms, mutual fund transfer forms and securities account forms, and retained these forms in his customer files contrary to his member firm’s prohibition against this practice.

Pletscher exercised discretion in customer accounts despite the fact that his member firm’s WSPs strictly prohibited discretionary trading in customer accounts, and he was aware of this prohibition.

The firm required that its registered representatives place trade orders immediately after receiving the customer’s authorization for trades, but at times Pletscher received oral authorization from customers to place trades in their accounts, yet he waited several weeks or months before placing the trades.

Pletscher requested to have variable annuity holdings for customers transferred into money market accounts without the customers’ authorization.  The customers requested the unauthorized transactions be reversed, causing his firm to incur reversal fees of $8,863.37.

Pletscher’s firm required its customers review and sign transaction related forms, but Pletscher instructed customers to provide transaction forms that contained only the customers’ signatures, which Pletscher later completed and submitted to the firm for processing, despite his firm prohibiting him from accepting incomplete forms from customers. Pletscher knew that by allowing his customers to pre-sign blank forms, he failed to ensure that customers had properly reviewed and understood the agreements they had signed. In addition, Pletscher caused the firm’s books and records to be false and misleading and to appear that the customers had agreed to the terms of each form on the date the forms were signed in blank.

Gould converted more than $1,315,000 from customers who had purchased annuities from him by, among other deceptive means and devices, convincing his customers to sign blank annuity withdrawal request forms, which he subsequently completed with instructions to the insurance companies to transfer his customers’ funds to a bank account held in the name of a company he owned and controlled. In some instances, the withdrawal request forms contained a medallion signature guarantee that he improperly obtained.

Gould converted funds from other annuity customers by using withdrawal request forms that contained customers’ signatures to direct insurance companies to transfer funds from the customers’ annuities to his bank account. Gould unlawfully converted customer funds from customers’ brokerage accounts by, among other deceptive means and devices, improperly transferring funds from their brokerage accounts to the bank account he owned and controlled. The customers either did not authorize or were not aware of the conversion resulting from the transfer of funds from their annuities and brokerage accounts to Gould’s bank account.

Gould used the unlawfully converted funds to pay for his own personal and business expenses; none of the customers were aware he was withdrawing funds for his personal use. On numerous occasions, Gould falsified documents to make it appear that customers had authorized the transfer of funds from their annuities and brokerage accounts to his bank account, and in some instances, effectuated these transfers by convincing customers to sign withdrawal request forms, some of which were blank.

Over a period of 10 years or longer, in face-to-face meetings with customers, Duvall had the customers supply account forms signed in blank, to support transactions the customers authorized. After obtaining information needed to complete the transactions, Duvall completed the forms and submitted them to his member firm for processing; but in some cases, he retained the blank, signed forms.

Duvall’s firm prohibited staff from obtaining or retaining documents the customers pre-signed, and Duvall was aware of the prohibition. Duvall caused his firm to violate NASD Rule 3110 in that he caused the firm’s books and records relating to customer accounts to be inaccurate.