Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2012
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.
David Vankuren Tolley
AWC/2010022046801
Tolley borrowed $5,000 from an investor and customer of his member firm contrary to his firm’s compliance manual that generally prohibited representatives from borrowing money from a customer unless the borrowing was made pursuant to an exception to the rule and written approval had been granted by the firm’s compliance officer; Tolley failed to obtain permission. 

Tolley failed to timely amend his Form U4 to disclose a material fact.
David Vankuren Tolley: Fined $7,500; Suspended 4 months
Tags: Borrowing  
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