Johnson affixed the signatures of members of the public on documents to open a joint account and transfer mutual fund shares into the account, without their knowledge and consent, and submitted the forms to her member firm for processing. Johnson had a registered sales assistant execute a “Signature Guarantee” for the customers’ signatures on the account transfer forms, based on Johnson’s representation to the assistant that she witnessed the customers sign the documents, which she knew was not true. During all relevant times, Johnson’s firm had a policy which prohibited representatives from signing documents or requesting anyone to sign documents on another person’s behalf, even if that person gave permission to do so. Johnson affixed one of the customer’s signature on a Letter of Instruction, which directed a member firm to sell $25,000 worth of the mutual fund that the customer owned, and forward the proceeds to Johnson. Although the customer authorized the transaction, Johnson affixed the customer’s signature to the document without the customer’s knowledge or consent, and bypassed her firm’s internal procedures requiring its operations department to review the document prior to submission to the mutual fund.
Johnson altered portions of an Individual Retirement Account (IRA) Distribution Request Form that another customer had completed by changing the date and dollar amount on the form; she then submitted the altered form for a distribution of funds. Although the customer authorized the distribution of funds, Johnson altered the form without the customer’s knowledge and consent.