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.
Howard Sang Lee
AWC/2009019154301
Lee
borrowed $20,000 from his customer and
repaid the loan in full,
plus interest. During the time of the
loan transaction, the firm’s
procedures specifically prohibited registered representatives from
borrowing money from
customers.
Lee’s conduct was aggravated by the fact that he failed
to disclose the loan
when completing the firm’s annual compliance inspection forms for
two years, when he
answered “yes” to the question, “Do you understand and comply with
the rule that you
cannot loan money to, or borrow money from your clients?”
Howard Sang Lee: Fined $5,000; Suspended 3 months