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Regulatory Sanctions

‘Willful’ Failure to Update Form U4 - FINRA Sanctions for November and December

December 18, 2017

by Howard Haykin


In November and December, FINRA cited at least 9 registered representatives for “willfully” failing to amend their Forms U4. The "Willful" label can be deathly injurious to an individual's career.  [NOTE: In some of the cases below, other alleged violations factored into the severity of FINRA sanctions.




Robert Hoffmann (FINRA AWC #2015045024901) - $5K fine & 3-month suspension.

  • willfully failed to timely disclose/report an unsatisfied IRS lien.
  • in November, was barred for failing to cooperate with FINRA’s investigation.


Nancy Johnson (FINRA AWC#2016049035301) - $10K fine & 5-month suspension.

  • made false written statements to her member firm on its forms and in its electronic distribution system in connection with the processing of a wire transfer request, falsely indicating that she and another employee had each spoken with the customer and confirmed the wire transfer request.
  • willfully failed to timely disclose/report a bankruptcy petition.


William White (FINRA AWC #2015048104602) - $12.5K fine & 16-month suspension.

  • willfully failed to timely to disclose/report a bankruptcy petition, tax liens, FINRA arbitrations and a civil litigation.
  • failed to timely respond to FINRA requests relating to an investigation.
  • opened and traded in an outside securities accounts without giving prior written notice to his member firm and the executing firm.


Tiffany De Ruosi (FINRA AWC #2015046161601) - $5K fine & 6-month suspension.

  • willfully failed to timely disclose/report felony charge in connection with a motor vehicle incident –reduced to misdemeanor in a plea deal.
  • provided false answer on firm’s annual compliance questionnaire (ACQ).


Kevin Bonner (FINRA AWC #2016049664001) - $2.5K fine & 6-month suspension.

  • borrowed $50K from customer without firm’s knowledge or approval; only repaid $25K.
  • willfully failed to disclose/report suspension of his accountant’s license by Washington State.


Evan Foehrkolb (FINRA AWC #2016052430501) - $5K fine & 6-month suspension.

  • willfully failed to timely disclose/report felony charges.
  • falsely answered on his member firm’s ACQ regarding the felony attestation.


Lawrence Koresko (FINRA AWC #2014043493201) - $10K fine & 6-month suspension.

  • willfully failed to timely disclose/report at least 12 civil lawsuits, all arising out of his outside business activities – all of which involved securities, were investment-related, or contained allegations of sales practice violations, as those terms are defined in the Form U4.
  • provided inaccurate answers on firm’s ACQs regarding receipt of customer complaints for securities or insurance.




Richard Riemer Jr. (FINRA AWC #2013038986001) - $5K fine & 6-month suspension – NAC/OHO rulings on appeal.

  • willfully failed to timely disclose/report tax liens and a bankruptcy petition.
  • falsely reported on firm’s ACQs regarding unsatisfied liens and bankruptcy filing.


Frederick Roehm (FINRA Case #2014041233001)- $5K fine & 5-month suspension.

  • willfully failed to disclose/report investment-related, consumer-initiated written complaint involving sales practice violations.
  • willfully failed to timely & accurately disclose/report his being named s a defendant in investment-related, consumer-initiated civil litigation involving sales practice violations.
  • attempted to settle the claims outlined in a draft complaint without notifying member firm.



[Click for simiilar Financialish write-ups posted in July 2017: 'Willful' Failure to Update One's Form U4 - Case Studies’]


These cases were reported in FINRA Disciplinary Actions for November 2017 or December 2017.

For details on any case, go to ...  FINRA Disciplinary Actions Online, and refer to the respective Case’s Number.