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.

Keith Lowell Epstein
AWC/2007008827601

Epstein received $280,500 from customers in their nineties to hold for distribution to a relative upon their deaths. Epstein deposited the funds in an account for a business he operated and distributed the funds to individuals other than the customers. Epstein knew that his member firm prohibited his acceptance, commingling and misuse of the customers’ funds, and after the firm discovered his activities, he repaid the customers. Also, Epstein failed to fully and timely respond to FINRA requests for information and documentation. 

Keith Lowell Epstein: Fined $10,000; Suspended 2 years in all capacities