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.

Sandra Loretta Guay
AWC/2008013937601

In an attempt to conceal a margin call and avoid the sale of stock, Guay transferred $2,100 of her own funds into a customers’ joint account to satisfy the margin call (the customers were unaware of the call). Prior to the margin call, one of the customers had expressed concerns to Guay about the account’s declining value.

A week later, Guay withdrew the $2,100 by completing an Authorization to Transfer Securities or Money form on the customers’ behalf by executing the joint account holders’ signatures without their consent or authority.When one of the customers questioned Guay about these transactions, she falsely claimed that there had been an “error” and failed to disclose her actions. Guay exercised discretion in the joint account without the customers’ prior written authorization and her member firm’s written acceptance of the account as discretionary. Guay executed numerous discretionary trades resulting in approximately $60,000 in losses.

Sandra Loretta Guay: Barred

Tags: Margin