Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2010
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.
Daphne Michelle Easley
2008013474501
Associated Person Easley misappropriated approximately $6,500 in funds from her member firm by ordering approximately $6,500 in gift checks, which were used by her member firm to reward employees, and converting the gift checks she ordered without authorization for her own use and benefit.
Daphne Michelle Easley: Barred
Bill Singer's Comment
I'm a bit puzzled by this one.  How the hell does an employee "order" $6,500 in "gift checks" that are supposed to be used to reward employees?  Did Easley simply fill out a form asking for, say, sixty-five $100 gift checks -- and no one at her firm thought anything unusual about that?  You would think that there would have been an additional supervisory layer in such a process whereby a second-party would need to review, authorize, and initial such a request.  I'm still trying to figure out what lousy safeguards would not only have accepted such a request but also fulfilled it.
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