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Regulatory Sanctions

Broker ‘Cuts and Pastes’ Herself Out of a Job

October 18, 2017

by Howard Haykin


Cutting and pasting a customer’s signature on a firm document is incredibly frivolous – and totally unnecessary – when you’re carrying out a customer’s instructions and trying to do right by that customer. If a broker with 8 years of experience with one firm resorts to such antics, one has to wonder how prevalent this practice is within the industry.


Say Nie Sam agreed to a $5K fine and a 2-month suspension to settle FINRA charges that she falsified wire transfer forms totaling $81,300 for a customer by affixing photocopies of the customer’s signature to the wire transfer forms and submitting them to her member firm as authentic documents from the customer.


BACKGROUND.    Say Nie Sam, a resident of Millbrae, CA, has 8 years of experience with 2 firms.  She was registered with Morgan Stanley as a General Securities Representative (Series 7) from 2008 until August 2016. She briefly registered with another FINRA member firm - from September to December 2016. Ms. Sam has no previous disciplinary history.


FINRA FINDINGS.    Between 5/20/16 and 7/13/2016 Ms. Sam falsified 5 wire transfer forms totaling $81,300 for a Morgan Stanley customer by affixing photocopies of the customer's signature to the wire transfer forms. While the customer didn't sign the wire transfer forms submitted to Morgan Stanley, the customer had authorized each transaction -  and all transactions were consistent with the client’s instructions.


That said, falsification of a business document violates FINRA Rule 2010.


This case was reported in FINRA Disciplinary Actions for August 2017.

For details on this case, go to ...  FINRA Disciplinary Actions Online, and refer to Case #2016051210501.