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Continuing Education: ‘Taking Unauthorized Shortcuts’ at Credit Suisse
Michael Dryden, Jay Kim and Peter Sack each agreed to settle FINRA charges that he permitted one or more administrative assistants to complete at least 5 firm-required eLearning modules for him, including an annual compliance certification.
For their (lack of) efforts, all 3 had to requalify as a General Securities Principal by passing the Series 24 examination within 60 calendar days of their settlement. In addition, each faced internal discipline, which included a Firm-imposed fine representing 10% to 20% of his respective 2015 incentive compensation payment and a requirement that he retake selected eLearning modules.
Here are the particulars:
Michael Dryden, who has 14 years’ experience with 2 firms, … is a Managing Director at Credit Suisse and was the Head of Special Situations Finance within Global Asset Finance in the Securitized Products Department at the Firm from at least 2013 until September 2016 when he became Head of Global Asset Finance.
- From October 2013 through February 2015, rather than complete each eLearning module himself, he provided his log-in credentials to 2 administrative assistants and requested that they complete 9 eLearning modules for him, including: (i) 2014 Annual Compliance Certification; (ii) "2013 Effective Supervision at Credit Suisse"; (iii) "Understanding Money Laundering, Terrorist Financing, Sanctions and Corruption;" and, (iv) "Operational Risk, Business Continuity and Information Security - 2014." (FINRA AWC #2015045496902)
Jay Kim, who has 29 years’ experience with 4 firms, … is a Managing Director and supervisor at Credit Suisse.
- From June 2013 through February 2015, rather than complete each eLearning module himself, he provided his log-in credentials to 2 administrative assistants and requested that they complete at least 5 eLearning modules for him, including: (i) 2014 Annual Compliance Certification; (ii) "Unauthorized Trading Awareness and Education Certification"; (iii) "Understanding Money Laundering, Terrorist Financing, Sanctions and Corruption"; and, (iv) "Global Records Management." (FINRA AWC #2015045496901)
Peter Sack, who has 16 years’ experience with 1 firm, … is a General Securities Principal at Credit Suisse.
- From October 2013 through February 2015, rather than complete each eLearning module himself, he provided his log-in credentials to an administrative assistant and requested her to at least 12 eLearning modules for him, including: (i) 2013 Annual Compliance Certifications; and, (ii) 2014 Annual Compliance Certification. (FINRA AWC #2015045496903)
These cases were reported in FINRA Disciplinary Actions for March 2018.
For details on this case, go to ... FINRA Disciplinary Actions Online, and refer to the Respective Case Numbers.