Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
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 2010
Clint Harley Keener
AWC/2007009431001/September 2010
Keener made unsuitable trade recommendations in a customer’s accounts by recommending purchases resulting in an overconcentration of non-investment grade bonds and other equities for a senior couple with no previous investment experience. Keener mismarked order tickets for purchases for these customers and other customers as “unsolicited” when they were “solicited.” Keener exercised discretion with verbal, but not written, authorization, in customers’ accounts, and although Keener frequently spoke to these customers, he did not speak to them every time he entered a transaction in their accounts. Keener did not have the customers’ or his member firm’s written authorization to engage in such discretionary trading.
Clint Harley Keener : Fined $7,500; Suspended 2 months
Tags:  Suitability        Discretion    Solicited     |    In: Cases of Note : FINRA
January 2010
Benjamin Gideon Geller
AWC/2007011920901/January 2010
Registered Supervisor Geller exercised discretion and effected numerous transactions in a customer’s account without obtaining written authority. When Geller placed the trades, he designated them as “unsolicited” although the trades were “solicited,” causing his member firm ’s books and records to be inaccurate.
Benjamin Gideon Geller: Fined $5,000; Suspended 90 days
Tags:  Discretion    Solicited     |    In: Cases of Note : FINRA
Enforcement Actions