Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2009
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.
Joseph Aloyisius Pramer III
AWC/2007009372601
Pramer altered customer telephone records at his member firm by deleting or inaccurately updating the numbers to slow down other registered representatives at his firm that he believed would be assigned to call his customers after he resigned. By changing customer telephone numbers, Pramer caused his member firm to create and maintain inaccurate books and records. 
Joseph Aloyisius Pramer III: Fined $5,000; Suspended 30 business days
Bill Singer's Comment
One of the oldest ploys in the book. Not excusing it -- BUT . . . . one of the reasons it exists is because of the nonsense (if not garbage) that goes on when an RR tries to leave his or her member firm.  And let's not pretend that everything is so lovey-dovey when your U5 hits your manager's desk and it's open season on your book.  If anything annoys me about Pramer, it's that this strikes me as the perpetuation of what I often see as a very lop-sided system or regulation that is lined up against most individual brokers. You leave and you're expected to toe the line and follow the rules about what you can and can't take.  However, member firms seems to have an arsenal of tricks that they can use to jam up departing RRs or try and persuade customers not to transfer.  You tell me -- how often do you see FINRA cases citing such practices?  Oh, yeah, that's right... I forgot ... only Member Firms get to vote at FINRA, not any human being brokers.  Maybe that's why things at the regulator often seem skewed in favor of management versus labor?
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