Associated Person Reed participated in a scheme that involved causing fraudulent checks to be issued and drawn from her member firm’s bank account. In connection with the scheme, Reed prepared fraudulent check requests and disbursed numerous checks drawn on her firm’s bank account in various amounts under $1,000 and totaling over $290,000. The checks were made payable to entities that did not provide services to her firm; this was done under the guise that the entities were firm-authorized transfer agents and the payments were for related fees.

Reed’s coworker provided her with fictitious billing invoices from such entities and, in turn, Reed initiated check requests through the firm’s computer system to pay the fictitious fees; the check requests were processed and approved, and the checks issued and delivered back to the securities processing area where she worked.

Upon receipt of the checks, Reed gave the checks to her coworker, who provided them to a third party not employed by the firm; in return for initiating and processing the fictitious check requests, Reed received periodic cash payments from her coworker, totaling an estimated $10,000, for her own personal use.

The firm became aware of this matter when the New York City Police Department contacted it regarding an individual (a non-firm employee) who was taken into custody in an unrelated matter; the individual was in possession of certain of the firm checks issued as a result of the scheme. In addition, the firm investigated the matter, including questioning Reed, who admitted that she engaged in the above-referenced conduct; the firm then terminated Reed’s employment.

Deroziere converted $10,000 from his member firm by endorsing and depositing a check made payable to the firm into his personal bank account without the firm’s knowledge or permission. Deroziere also converted $750 from a nonsecurities customer by endorsing and depositing checks made payable to the customer into his personal bank account without the customer’s knowledge or permission. Deroziere failed to respond to FINRA requests for information.

Without a bank customer’s knowledge or authorization, Barrett

• signed the customer’s name on a check withdrawal form requesting a $25,000 check from the customer’s account made payable to Barrett’s friend, and the funds were later deposited into the friend’s checking account; and
• activated and linked an ATM card to the bank customer’s savings account and used the card to withdraw $3,500 from the account for his own personal use and benefit.

Barrett failed to respond to FINRA requests for information and to appear and testify at an on-the-record interview.

McEwen converted $32,528.56 from a customer by falsely informing her that a check McEwen’s member firm sent to her pursuant to a consent order with the Missouri Securities Division for unsuitable variable annuity sales to the elderly was sent to her by mistake and actually represented commissions the firm owed him. McEwen instructed the customer to deposit the check into her bank account and then make a check payable to him in the same amount; after the customer followed these instructions, McEwen cashed the check and deposited the funds into his personal bank account. McEwen converted an additional $11,000 from the customer by depositing checks intended for investment into his personal bank account and failed to purchase investments on the customer’s behalf.

McEwen failed to appear for FINRA on-the-record testimony.