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.
Frick engaged in outside business activities and private securities transactions without prior written notice to her member firm. Frick was provided a money order by a customer in order to open an account at her member firm on behalf of the customer’s children, misplaced the money order and, in an attempt to settle the customer’s potential complaint in this matter, deposited $1,100 of her own personal funds into an account at her firm for the benefit of the customer’s children without notifying the customer or the firm. Frick used the funds she had previously deposited into the account to purchase mutual funds for the account without the customer’s knowledge, authorization or consent.