[ by Howard Haykin ] Perhaps - but that's our take. This Cincinnati-based Registered Rep agreed to settle FINRA charges that, she signed the names of her member firm’s brokers on new account forms without authorization, while working as a Financial Consultant Associate with PNC Investments. The Respondent. Ann Josephson first became registered with FINRA as a General Securities (Series 7) Rep with Salomon Smith Barney in May 2001.  Over the years, between 2001 and 2009, she held registered positions with several different FINRA member firms.  Josephson was with PNC in a registered capacity from August 2009 until her termination from the firm on November 2010.  Josephson has not since been associated with a FINRA member firm. FINRA Findings and Allegations. During the relevant period, Josephson served as a Financial Consultant Associate with PNC, and was assigned to assist 3 brokers with general administrative duties that included scheduling appointments and meetings with clients to complete transactions, fulfilling client service requests, and assisting in sales support of their clients.  As part of these duties, Josephson assisted with the completion of customer new account documentation.

[C-I Note: Let's stop here for a moment and consider the circumstances.  Ms. Josephson arrives at PNC in 2009, having been a General Securities Rep for 8 years, and having  worked for several firms.  Now, admittedly, we know very little about Ms. Josephson - what work she did or what positions she held for those other firms, or whether she came to PNC with the intent of being a full-fledged broker, with her own book of business and customers whom she would call on.

We only bring this up because, PNC has given Ms. Josephson some rather menial responsibilities - even though she's been in the business, in a registered capacity, for some 8 or 9 years.  It just seems strange - or better yet, awkward - that she would do clerical work for 3 brokers.  We'll continue after the next section.]

Anyway, between January and November 2010, Josephson signed the names of two brokers on a total of 10 customer new account forms without authorization to sign the forms.  The forms were for PNC internal use only, and did not authorize the trading of any security.  She didn't try to disguise the fact that she signed for 'her' broker - because she did so in her own handwriting - and anyway, the purpose was to expedite the customer paperwork.

[C-I Note: Now, it would be quite possible that Ms. Josephson signed the brokers' names on the forms at the request and consent of the brokers, themselves.  We don't know that for sure, but it's what we surmise.  We can hear the brokers saying, "Oh, c'mon Ann, do me the favor if I'm not around and sign the form.  It's no big deal."

Then, lo and behold, FINRA pops into the (branch?) office to conduct a sales examination, and they come across these 10 new account forms.  If the brokers admit the truth, they will be fined and suspended.  Better to have the "admin" take the blame - which she did.  BTW, she's no longer in the industry - which may or may not be relevant.]

Cited Violations and FINRA Sanctions. The signing of brokers names, supposedly without their authorization or consent, would be a violation of FINRA Rule 2010.   For her alleged "forgeries" Josephson had to pay a $5K fine and was suspended for 2 months.  As we said earlier, she dropped out of the industry after this matter. It's anyone's guess as to what happened, but we've seen this scenario several times before, and always have the same gnawing feeling that the individual is simply playing the "Fall-Guy" or "Fall-Gal."  DK - don't know.  Refer to [FINRA Disciplinary Actions for June 2012]. For further details, go to:   [FINRA AWC #2010025326101].