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NEWSLETTERS & ALERTS
Reducing Fraud in the Broker Dealer
May 17, 2012
[ by Melanie Gretchen ]
If you're going to commit fraud, steal from your clients, or otherwise get away with as much as possible to the point of detection, the time is now. The latest trend of May 2012's Disciplinary and Other FINRA Actions plays like a bad soundtrack: a theme of dishonesty, evasion, and just plain cheating runs through the month like a new classic, because this trend isn't going away soon. Just a few choice examples:
Matthew W. East took his creativity to life insurance applications in his role as RR out of Des Plaines, Illinois. Using correction fluid, he altered or falsified conversion applications; in one instance taped over a customer's signature he had cut out of another form. At least 2 altered life insurance policy applications were not approved by customers.
In the same vein, East took it upon himself to add a renter's policy rider to a customer's automobile insurance policy without the customer's authorization and later converted the renter's policy rider to a standalone renter's policy without the customer's authorization. After the customer complained, the insurance brokerage cancelled or suspended the renter's policy and the life insurance conversion applications supported by falsified forms, following an internal investigation. [CI Note: Can you blame him? He got away with it before.]
Carolyn Avia Harmon. Taking East's activity one step further, Harmon used customer forms expressly for her own benefit. In her capacity as an office administrator in Lenoir, North Carolina, she funneled customer funds into a relative's account, which she created, without the relative's knowledge or consent. Following that success, she then transferred most of that money into her own account.
In addition, she transferred customer checks into another firm account she held jointly with her relative. When not failing to respond to FINRA requests for information, she initially said the checks had been the result of an administrative error, as well as that they may have represented compensation to her relative for work he had done for those customers. To date, she had misappropriated more than $63,000 from several of her associated firm's customers. [CI Note: Did Harmon really think the checks she deposited would not be traced? Was she reckless, or desperate to help her relative, as she finally confessed?]
Rudolf Lucian Molnar. Who needs paperwork when you just pretend to be your customer? Unlike East and Harmon, Molnar acted on the behalf of his customers to expedite the transfer of their accounts from his former broker-dealer to his new one. The process work like this: he called his former broker-dealer, identified himself as the customer, and proceeded to impersonated the customer, sometimes using the customer's personal information.
For his actions - which were not authorized by the customers, though the transfers of their accounts were - he was suspended for 6 months, from 4/16/12 through 5/15/12. [CI Note: Perhaps a new career is waiting in the wings?]
Take Away. In cases like these where the perpetrators succeeded for so long, one has to wonder whether they should have been better at covering up their activity because the system is so conducive to their actions. If institution of the Volcker Rule is any indication, the system itself isn't going to get better anytime soon. East and Harmon were suspended from activity with any FINRA member in any capacity for their actions, for which we commend Finra. Yet, why did it take so long for these actions to be detected? Because they banked on getting away it.
For further details, go to [May 2012 Disciplinary and Other FINRA Actions].

