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FINRA Q3 Disciplinary Highlight #5: Knowingly Submitting False Documentation

October 13, 2010

In today's case, an RR knowingly engaged in a scheme that enabled him to open 43 accounts for unqualified individuals and make $800 in commissions.  He submitted false customer documentation for customers he solicited to open banking and investment accounts.   

While the RR understood that the employer required photo ID's and written verifications of residential address when a customer opened an account, some of his customers were undocumented, non-U.S. citizens who were paid in cash by their employers.  They rarely maintained established residences in the U.S. and they always carried their cash holdings with them.  Those who tried to open bank or investment accounts to deposit their funds, supposedly were often unable to comply with the firm’s requirement for proof of residence. 

The RR thought he'd overcome this obstacle by having an unregistered colleague create and sign false address verification letters for the RR's potential customers.  The letters, on the company’s letterhead, falsely represented that the customers worked for the colleague and resided at an address indicated in the letter.  The RR submitted the falsified letters over a 2-month period, and earned $800 in commissions for opening the accounts. 

For having allegedly violated NASD Rule 2110, RR was fined $10,000 and suspended 6 months.   [ FINRA Quarterly Review, October ]

[C-I Note:    Interestingly enough, had greed not been an issue - he brought in unqualified customers only for the $800 commission - the situation might almost appear sympathetic.  Imagine the RR who's simply trying to do something good for hard-working individuals who can't seem to catch a break - a form of community service, if you will.]