Neumeyer affixed customer signatures and a registered representative’s name on documents without their knowledge or consent. During the course of routine review of account documents, Neumeyer’s member firm notified a registered representative whom Neumeyer assisted, that corrections were necessary on certain account documents, including obtaining customer signatures on forms for a number of accounts. Neumeyer sent by fax to her firm the documents with corrections that had been requested and upon review of the account documents that Neumeyer faxed, certain customer signatures were identified as appearing to have been cut and pasted on to the forms.
When Neumeyer was questioned about the suspected falsified documents, she admitted to altering the documentation for a customer, by cutting and pasting the customer’s signature on separate forms without the customer’s knowledge or consent; the forms included disclosures about the nature of the customer’s investments.Neumeyer also signed the name of the registered representative whom she assisted on numerous different documents for a number of different customers. The forms on which Neumeyer signed the registered representative’s name were acknowledgments that the registered representative reviewed the customer account documents “for completeness, accuracy, suitability and proper disclosures” and acknowledgments that the registered representative had scrutinized the customer’s information in compliance with the Office of Foreign Asset Control (OFAC) and the customer identification program (CIP), relating to the firm’s compliance with AML rules.