Subscribe to our mailing list

* indicates required







We seek to provide information, insights and direction that may enable the Financial Community to effectively and efficiently operate in a regulatory risk-free environment by curating content from all over the web.


Stay Informed with the latest fanancialish news.




Investments - Unsuitable

Broker Double-Dips into Customers’ Accounts

April 23, 2020

[Seinfeld 'Double Dip' Episode featuring George Costanza / YouTube Screen Grab]


by Howard Haykin



Double-Dipping is defined as …
  1. Obtaining money from 2 places at the same time, sometimes in a way that is not legal.
  2. Repeating the action of dipping a chip or other snack into a shared dipping sauce or mixture after taking a bite.
[Cambridge Dictionary, Merriam-Webster Dictionary]



A broker with Morgan Stanley cheated 8 customers out of $58,000 by double-dipping into their brokerage and fee-based accounts. Between January 2014 and December 2016, the broker recommended that his customers purchase 28 municipal bonds and 15 non-municipal securities in their brokerage accounts, where upfront sales commissions were charged. Within 90 days of each trade, the broker transferred the securities to the customers’ existing fee-based accounts.



DOUBLE DIPPING.    The upfront sales commissions associated with the 43 purchases cost the customers a total of $58,000. Had these recommended purchases been made in the fee-based accounts there would have been no sales charges - because the customers were already paying annual fees of perhaps 1% or 2%. So, by collecting an ill-gotten brokerage commission on top of Morgan Stanley's annual advisory fee, the broker essentially double charged his customers for the services provided by Morgan Stanley and himself.


Upon learning of the double-dipping, Morgan Stanley terminated the broker. FINRA followed up by suspending him and hitting him with $29,000 in fines and disgorged commissions.



KEEP IT SIMPLE; KNOW YOUR CUSTOMER RIGHTS.    A single account for each beneficiary is usually all that most customers need. Should a broker suggest more than one account, don't do anything until you get a clear and unambiguous explanation for the purpose of each account, along with an explanation as to how the multiple accounts will interact with each other. If unsure what to do, get another opinion from a trusted independent source – a friend, a family member or a Financial Watchdog. Keep It Simple; Ask Questions; Understand Your Customer Rights.



[For further details, click on … FINRA Case #2018057097301​.]