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.
Jose Ricardo Santillan
AWC/2008016181501
Santillan removed information regarding a FINRA qualification examination from a testing site. He made handwritten notes, which included examination questions and potential answers, and removed them from the testing site. Santillan electronically confirmed his agreement to the rules of conduct and agreed to maintain the confidentiality of the examination materials, including the examination questions.
Jose Ricardo Santillan : Barred
Tags: Testing  
Bill Singer's Comment
When I started reading this case I thought it was going to be about a test "cheating" violation.  We saw frequent reports of those matters in years past, where the test-taker was caught using notes, looking at someone else's answers, or impersonating another indivdual.  Here we have a very odd variant.  Doesn't seem that Santillan was cheating on the exam as much as he was trying to memorialize the actual questions.  Perhaps he was sent in to the testing facility by an organization that trains wannabes seeking registration; or maybe he was planning to bring his notes back to the office and make it easier for his buddies to prepare?  Anyway, at least it was a break from the mundane
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