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.
William Ray Collins Jr
AWC/2008013648001/September 2010
Collins forged customers’ signatures on financial documents and submitted the documents to his member firm and failed to send a copy to the customers.
Collins failed to disclose a variable annuity service fee in his discussion with customers and, when the customers inquired about the fee, Collins told them that the fee was an error; and to avoid further inquiries he used his own funds to pay the fee without informing the firm or the customers. Collins accomplished his payment of the fees when he executed money orders on the customers’ behalf, forged the customers’ signatures on the money orders and submitted the money orders to the firm to pay the variable annuity fees that he had not disclosed to the customers.
William Ray Collins Jr: Barred
Jarem Barry Bingham
AWC/2009017621401/August 2010
Bingham gave a member firm customer $4,421 to compensate her for tax consequences incurred as a result of his recommendation that the customer liquidate a variable annuity and purchase mutual funds with the proceeds. Bingham acted without his firm’s knowledge or authorization when sharing in the customer’s loss, and his firm’s procedures prohibited representatives from paying or offering to pay restitution to a customer. Bingham loaned customers approximately $1,050 because of delays in processing their withdrawal requests, which the firm’s procedures prohibited.
Jarem Barry Bingham : Fined $10,000; Suspended 15 business days