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.

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AWC/2009020797001/January 2012

This couple received checks totaling $55,180.29 from a customer to be applied to the  couple's mortgage and were intended as loans, without notifying their respective firms of the loans and without obtaining approval to receive the loans. The couple's’ firms had policies and procedures that generally prohibited lending arrangements between the firms’ representatives and customers, with certain exceptions. Those exceptions did not apply to the loans between the customer and the couple's. The firms required that a representative receive pre-approval for any lending arrangement between the representative and a customer of the firms. The couple's have not repaid the loans. 

Tags:  Borrowing    Mortgage     |    In: Cases of Note : FINRA