I keep re-reading the charge here and, frankly, I find myself scratching my head because although I think that I understand, to a limited extent, what happened here, I'm not exactly sure I understand how this added up to both a $5,000 fine and a 60-day suspension.
The customer service representative prepared an internal administrative form (that's worth repeating: it's an internal form that's used only for administrative purposes). This form was used to document and process for branch managers and FAs, requests received "verbally" from a customer. FINRA charged this service rep for preparing the form that apparently accurately reflected the customer's verbal request but the service rep engaged in the apparently violative activity of signing the manager/FA's name on the internal administrative form.
I'd like to know how many other service reps at this member firm had engaged in this same "signing" practice and for how long. I'd also like to know whether it's FINRA's position that the managers and FAs involved were shocked, absolutely shocked, when they learned that all of these customer requests were processed without their signatures -- and then I'd like to know just how the hell those managers and FAs thought the requests were submitted on those forms if they hadn't signed them.
When I looked up the underlying AWC, I learned that FINRA charged Knieriem with having engaged in the misconduct between March and September 2010 (that's six months) and having submitted ten "forged" forms on behalf of three FAs and one manager.
As you can tell, I'm not exactly thrilled with what I view as the harsh nature of this sanction. It may be justified but not solely based upon the facts presented by FINRA, as far as I'm concerned.