In this case, penmanship didn't count
For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Jordan R. Steel submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Jordan R. Steel, Respondent (AWC 20110296194-01, July 27, 2012).
Steel is a Canada-Limited General Securities Registered Representative who entered the securities industry in August 2007 with Canaccord Wealth Management, where he remained until the October 5, 2011, termination of his registration. The AWC asserts that he had no prior relevant disciplinary history.
The AWC alleges that Steel had an agreement with another Canaccord registered representative whereby Steel received 1.5% of that other rep's commissions from transactions involving U.S. customers. In order to receive his share, about every month, Steel would enter what he had calculated was the sum due to him on an Assistant/Associate Bonus/Commission Requisition Form (the "Form"). Thereafter, the other registered rep's signature needed to be added to the Form and, subsequent to that, the signed Form was submitted to Canaccord for payment.
18 After The Fact
The AWC alleges that from January 6, 2010, through August 3, 2011, Steel falsified 18 of the Forms by altering the amount due to him on each form afterthe other rep had signed off but without that individual's knowledge or authorization.
13 Besides The Fact
Additionally, from August 11, 2010, through August 3, 2011, the AWC alleges that Steel completed 13 Forms requesting a commission share involving a second rep, and that this other individual's signature was falsified on the forms without that party's knowledge or authorization. Moreover, unlike with the first registered rep, the AWC alleges that no commission sharing agreement existed between Steel and the second rep.
Finally, the AWC alleges that the payments made to Steel as a result of the above submitted forms between January 6, 2010 and August 3, 2011, resulted in Cannacord paying to him $66,000.00 (Canadian dollars) in commissions to which he was not entitled.
The AWC alleges that by falsifying 31 Forms and intentionally accepting payment of commissions to which he was not entitled, Steel violated FINRA Rule 2010. In accordance with the terms of the AWC, FINRA imposed upon Steel a Bar from association with all FINRA members in all capacities.