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Regulatory Sanctions

FINRA ‘Conversion Therapy’ for Expense Report Cheaters

January 18, 2019

by Howard Haykin


CHEATING ON EXPENSE REPORTS IS BAD BUSINESS. That’s because the penalties for getting caught far exceed any possible incremental gains one can ‘make’ by requesting reimbursement for false or exaggerated business-related expenses.
CONVERSION is the intentional and unauthorized taking of, or exercise of ownership over, property by one who neither owns the property nor is entitled to possess it. CONVERSION violates FINRA Rule 2010 even if the person from whom the property is converted is not a customer of the firm with which the respondent is associated.



In January 2019, FINRA reported disciplinary actions against 2 associated persons who submitted false expense reports. Both were barred from the industry. Here are their details.


A GENERAL SECURITIES REP AND RESEARCH ANALYST WITH ODEON CAPITAL GROUP … converted $5,000 from her member firm by deliberately submitting false claims for business expense reimbursement. From January 2017 to August 2017, the Analyst submitted approximately 50 expense reports for reimbursement in which she deliberately mischaracterized various personal expenses - mostly meals - as business-related expenses involving customers or potential customers.


  • In October 2017, the Analyst was U5’d for "failing to cooperate during an internal investigation of [her] expense report submissions."
  • In May 2018, the Analyst pleaded guilty in the NYS Supreme Court to a misdemeanor charge of falsifying business records by submitting fraudulent expense reports and paid $5,000 in restitution to Odeon.
  • [FINRA AWC #2017055921701]



A GENERAL SECURITIES SALES SUPERVISOR WITH MERRILL LYNCH PIERCE, FENNER & SMITH … converted $1,959.80 from his member firm by submitting false expense reports. From December 2014 to November 2016, the Sales Supervisor on multiple occasions intentionally overstated the mileage expenses he incurred when visiting various Firm branch offices. Specifically: (i) for November 2015, he claimed mileage expenses of $2,268, though at least $1,355 of those expenses were fictitious; and, (ii) for October 2016, he claimed mileage expenses of $604.80, though he never actually incurred those expenses.


  • In November 2016, the Sales Supervisor voluntarily resigned, while he was the subject of an internal review..
  • In December 2016, Merrill Lynch U5’d the Sales Supervisor after "[t]he Firm's review determined that [he] made improper submissions of personal expenses for reimbursement."
  • [FINRA AWC #2016052411501]



FINANCIALISH TAKE AWAYS.    About half the associated persons who are caught cheating on expense reports end up getting barred from the industry. The other half get $5,000 fines and long-term suspensions (6 to 12 months). As noted above, cheating on expense reports is a losing proposition. Need proof? Click on any of these recent Financialish postings. 



These cases were reported in FINRA Disciplinary Actions for January 2019.

For details on either case, go to ...  FINRA Disciplinary Actions Online, and refer to the Respective Case Number.