Page converted a total of $1,207,440.61 from retail customer brokerage accounts by arranging for transfers of funds from the customers’ accounts, by way of one check and automated clearing house (ACH) debits, for payment of a corporate credit card account held in her name, without the customers’ authorization.
Page provided false information to a Certified Public Accountant (CPA) who was acting on one of her customer’s behalf with respect to some of the ACH debits made from that customer’s brokerage account totaling $286,330.72, each debit having been made payable to Page’s corporate credit card account.
Page told the CPA that the debits were made to fund an outside real estate investment in which she had placed a portion of the customer’s investment portfolio. Page fabricated an account statement purportedly demonstrating that the customer had an ownership interest in a particular REIT when no such ownership existed, and faxed the fabricated statement to the CPA. When the CPA sought further information about any dividends arising from the REIT investment, Page falsely explained to the CPA that while dividends were expected, they would not be forthcoming until the following tax year.
By deliberately deceiving one of her customer’s appointed representatives in such a fashion, Page, in the conduct of her securities business, failed to observe high standards of commercial honor and just and equitable principles of trade.