Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
UNDISCLOSED SETTLEMENTS
2010
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.
Robert Paul Aamodt (Principal)
AWC/2009016700301
Aamodt reimbursed a customer for losses in a family limited partnership account that resulted from a trading error. Aamodt wrote a personal check made payable to the account to offset the losses that occurred due to the decline in price of the purchased shares. Aamodt admitted the trading error and his subsequent actions to his member firm, which reimbursed the customer all remaining losses plus interest lost as a result of the trading error; subsequently, Aamodt repaid the firm.
Robert Paul Aamodt (Principal): Fined $5,000; Suspended 5 days in all capacities
Bill Singer's Comment

These so-called Undisclosed Settlements happen.  Sometimes they are well-intentioned to the extent that the RR figures it's simply easier to go to an ATM, give the complaining customer some cash, and be done with it (even if the RR is convinced that he or she did nothing wrong). Other times, these sub rosa settlements are done to avoid detection by the member firm and to fly under the regulatory radar.

To Aamodt's credit -- and which likely explains the relatively light sanctions -- he fessed up to his firm and fully repaid the employer for its reimbursement to the client.

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