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.
Daniel Michael Doderer
In connection with the opening of a new account for an existing institutional client, Doderer signed the names of officers for that client on sections of a Uniform Application for Investment Advisor Registration (Form ADV), without the signatories’ authorization or consent, and added false dates to sections of the Form ADV. Doderer submitted the Form ADV in connection with the opening of another account for the client, his member firm rejected it because it lacked a manual signature. Rather than obtain the signatures from the institutional client, Doderer signed the name of the client’s vice president next to the electronic signature on the domestic investment adviser execution page and state registered investment adviser execution page on the Form ADV, and inserted a false execution date on the execution page. Doderer signed the name of the client’s president and inserted a false execution date on the non-resident investment adviser execution page of the Form ADV. Doderer signed the officers’ names without their authorization or consent and submitted that Form ADV to the firm.
Daniel Michael Doderer: Fined $5,000; Suspended 1 month