RR falsely prepared a letter on the letterhead of one of his member firm’s institutional customers without the customer’s or firm’s knowledge or authorization. RR addressed the letter to the customer’s plan vendor, directing the plan vendor to change the commission split on the customer’s 457 plan to reflect that RR would receive a 100 percent commission; originally, the customer’s plan revenue reflected a commission split of 96 percent to RR and 4 percent to another registered representative.
RR’s member firm agreed to have commission revenues flow solely to him in the short term after the other registered representative resigned, but advised him that he needed to obtain a letter from the customer acknowledging his role as the sole broker of record due to the other registered representative’s resignation. The letter purportedly authorized RR to receive 100 percent of the commission from the plan revenue, and RR forged the signature of the customer’s plan controller without her knowledge or authorization. RR’s firm policy prohibits a registered representative from signing a customer’s signature to any paperwork, regardless of whether the customer has given permission to do so, and prohibits a registered representative from signing a client’s name on any form, with or without the client’s authorization.