Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
U4, U5, RE-3, RULE 3070
2009
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 2009 - View all for this month
Stephen Timothy Crawford
OS/2008013892301

Crawford borrowed $25,000 from customers and obtained this loan notwithstanding the fact that his member firm had written procedures that prohibited borrowing from, or lending money to, customers. Crawford failed to update his Uniform Application for Securities Industry Registration or Transfer (Form U4) to disclose material information. Crawford failed to respond to FINRA requests to appear for on-the-record testimony. 

Stephen Timothy Crawford: Fined $5,000; Suspended 2 years
Bill Singer's Comment
By now, this is a fairly standard "borrowing" case set of facts. What I find a tad curious is that in addition to the borrowing violation, we have U4 and a "failure to respond" charges. Frankly, I would have expected a bar or a far more serious sanction. Either Crawford had a superb lawyer or FINRA interpreted the three violations differently than the case report implies.
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