Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CASES OF NOTE
2011
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.
September 2011 - View all for this month
Julia Merritt Cameron
AWC/2010023339801
Cameron borrowed $1,500 from one of her customers at her member firm, which was repaid but did not seek approval for the borrowing and did not otherwise obtain approval from the firm to borrow money from the customer. When the borrowing occurred, the firm required representatives, before borrowing money from a customer, to obtain a designated official’s written approval. Cameron did not disclose to the firm that she had borrowed money from a customer.
Julia Merritt Cameron : Fined $2,500; Suspended 10 business days
Tags: Borrowing  
Bill Singer's Comment
I'm often asked by clients what FINRA's sanctions could be if they borrowed money from a client, repaid it, but, well, you know, just between you and me, sort of didn't tell the firm about it.  Allowing for the fact that there is no one-size-fits-all sanction and that all alleged violations have to be viewed on their own, it's still a fairly good indication that if you borrow and repay but did the borrowing in violation of your firm's policies, that you may likely be looking at a $2,500 fine plus 10 business days of downtime.  HOWEVER, as I said, that's not a sure thing.
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