Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2011
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.
November 2011
Kristen Anne Jacques
AWC/2010024077701/November 2011
Associated Person created expense reports associated with personal expenses charged to her member firm-issued credit card, which she ultimately paid. Each expense report, Jacques labeled each expense as ďpersonalĒ and attached a check to reimburse the firm for the personal expenses charged. Jacques signed her supervisorís signature on a line on each expense report titled ďauthorized approval signature,Ē and stamped her supervisorís printed name on a line with the instruction ďprint approver name.ĒJacques submitted the expense reports to the firm; neither the firm nor Jacquesí supervisor gave her permission or authority to add her supervisorís signature to the expense reports.
Kristen Anne Jacques: Censured; Fined $5,000; Suspended 1 year
Tags:  Expenses     |    In: Cases of Note : FINRA
Bill Singer's Comment
For a more detailed analysis of this case, read: http://www.brokeandbroker.com/1070/goldman-sachs-kristen-jacques-credit-card/
Tracey McInchak
AWC/2010022690601/November 2011
Associated Person McInchak wrote numerous checks, totaling $461,013.14, from her member firmís corporate checking account made payable to herself and to her personal credit card companies. McInchak cashed the checks and used them for her own benefit without the firmís knowledge or permission.
Tracey McInchak: Barred
Tags:  Checks    Credit Cards    Expenses     |    In: Cases of Note : FINRA
Bill Singer's Comment
How nice!  You just get some checks that are laying around, write them out to yourself, and, voila!!, nearly half a million dollars later you're a very happy camper.  I'd love to know what system of checks and balances were in place here.
October 2011
David Do-Yong Lee
AWC/2010023019701/October 2011
Lee misappropriated $900 from his member firm by claiming and receiving reimbursement for personal expenses, which he claimed as business expenses, thus converting his firmís funds to his own use. Lee caused his firmís books and records to be inaccurate.
David Do-Yong Lee: Barred
Tags:  Expenses     |    In: Cases of Note : FINRA
Jaime Campos Lopez
AWC/2009018640401/October 2011

After discussing with his member firm the possibility of him participating as an exhibitor during a dental convention by representing the firm at a booth in the exhibition hall and distributing literature, Lopez did not follow up and formally request permission, contrary to the firmís written procedures. Despite the lack of the firmís approval, Lopez arranged for and participated as an exhibitor representing the firm by staffing an exhibition booth at the convention and distributed, or had available for distribution, literature about the firm and himself. 

Lopez provided FINRA with inaccurate and misleading information.

Jaime Campos Lopez : Fined $5,000; Suspended 2 years
Tags:  Expenses     |    In: Cases of Note : FINRA
July 2011
Kimberlie Munsie Clark (Principal)
AWC/2010025003701/July 2011
Clark was her firmís Chief Financial Officer and co-Chief Operating Officer with authority to write checks from its checking accounts, including checks for her own compensation, and she misappropriated $8,333.33 from her member firm. Clark was entitled to a payroll check in the amount of $8,333.33 and issued a check to herself for that amount and, without the firmís permission, issued herself another $8,333.33 check. Both payroll checks were deposited in Clarkís personal banking account.
Kimberlie Munsie Clark (Principal): Barred
Tags:  Checks    Expenses     |    In: Cases of Note : FINRA
Bill Singer's Comment
How sad to destroy a career over something so relatively petty.
May 2011
Michael Paul Dickamore
2009017212301/May 2011
Dickamore used his member firmís corporate credit card for personal expenses in the amount of $50,413.56 without the firmís permission or authority, and submitted the charges as business expenses for the firm reimburse. During an interview with his firm, Dickamore admitted that he purchased personal items with his corporate credit card and falsely identified those items as business expenses. Dickamore reimbursed the firm in full. but failed to respond to FINRA requests for information and failed to appear for on-the-record testimony.
Michael Paul Dickamore : Barred
Tags:  Expenses    Corporate Credit Card     |    In: Cases of Note : FINRA
April 2011
Christopher Malchin
AWC/2010021389601/April 2011
Malchin utilized his business credit card for personal expenses and submitted false expense reports to his member firm, pursuant to which he was reimbursed approximately $1,806 for expenses that were not business-related.
Christopher Malchin : Fined $5,000; Suspended 6 months
Tags:  Credit Cards    Expenses     |    In: Cases of Note : FINRA
Bill Singer's Comment
For a while there, this type of violation was popping up with some regularity but I haven't seen that same flood of credit card/expense cases during the past couple of years.  Guess, the trickle is beginning again.
DaLean Annette Rials (Supervisor)
AWC/2009019405601/April 2011

Rials misappropriated approximated $70,000 from her member firm. Rials, as operations manager of her firmís branch office, had authority to approve credits to customer accounts up to a specified dollar amount without additional approval. Rials used this authority to credit reimbursements totaling approximately $50,000 for non-existent fees and expenses in accounts belonging to her friends and family. Rials then withdrew the credited amounts from family accounts or received cash or checks from friends for the credited amounts.

Rials submitted expense reports for approximately $20,000 in personal expenses, falsely identifying them as legitimate business expenses. Rials improperly accessed her supervisorís computer and approved some of her own expenses reports.

DaLean Annette Rials (Supervisor): Barred
Tags:  Expenses    Computers     |    In: Cases of Note : FINRA
Bill Singer's Comment
Frankly, wow.  Gotta giver Rials some credit. I mean, you know, as far as these things goes, this one was somewhat clever. $50,000 in bogus fees/expenses and another $20,000 for bogus expenses. And, to top it all off, she uses her supervisor's computer to clear the transactions.
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