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Barred for Borrowing (from Customers)
FINRA "threw the book" at 3 registered persons, including one principal, who borrowed from one or more firm customers - unbeknownst to their member firms. Here are their stories.
For complete reads, click onto: [FINRA Disciplinary Actions for December]
1. Registered Rep Koerner, Wautoma, WI, agreed to be barred from the industry, to settle FINRA charges he borrowed $94,000 from a firm customer in contravention of his member firm’s compliance manual, that generally prohibited RR's from borrowing money from a customer other than a financial institution or a family member. Koerner sealed his fate by failing to respond to FINRA requests for information ("RFI"). (FINRA Case #2009019876801)
2. Registered Rep Lamoreaux, Phoenix, AZ, agreed to be barred from the industry, to settle FINRA charges she borrowed money from her member firm’s customer without seeking the firm’spermission to borrow the funds and against the firm’s borrowing procedures, which required its RR's to obtain prior approval. The firm repaid the customer the loan amount plus interest. Lamoreaux sealed her fate by failing to respond to FINRA RFI's and to provide testimony. (FINRA Case #2009019285301)
3. Registered Principal Mills, Carmel, IN, agreed to be barred from the industry, to settle FINRA charges he borrowed $317,000 from elderly customers, promised to pay interest and repay the principal in full by certain dates, but failed to repay the loans or interest. Mills’ member firms were unaware of, and had not approved, the loans. One of the firms allowed lending arrangements - though under certain arrangements and Compliance's prior written approval; the other firm prohibited any borrowing from customers. (FINRA Case #2008015357301)

