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 Michael Scaffe
AWC/2008013809702

Scaffe borrowed funds from member firm customers when the firm expressly prohibited its representatives from borrowing funds from customers and included such prohibition in its compliance manual. Scaffe signed annual compliance questionnaires on which he acknowledged that he had received or had access to the firm’s compliance manual and did not request or obtain permission from his firm to borrow funds from customers, nor could he under the firm’s procedures. Scaffe failed to respond to FINRA requests for a written statement.

David Michael Scaffe: Barred

Tags: Borrowing