Okay, just to be clear, very, very clear, I absolutely detest and hate this case. A fairer resolution would have been to send Kang a sternly worded letter explaining why she should not do this and how it was necessary to obtain pre-approval from her firm. Nontheless, under the totality of the circumstances, I find it absurd to impose a $7,500 fine upon the RR. Moreover, I see no reason to sit her down for 60 days.
Justice is not blind. Justice wears a blindfold. Every so often, Justice needs to lift the blindfold and take a peak. The reality of this case is that a broker lent a large amount of money to a friend in order to help out with a business issue. The broker did not borrow the funds from the client. Yes -- I know, the rule prohibits both borrowing and lending. And, yes, I respect why such a rule is in place and am not disputing its wisdom. However, sometimes you just need to dilute the consequences when the underlying facts argue for some compassion and leniency.