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, David Andrew Renn submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of David Andrew Renn, Respondent (AWC 2012031041701, November 27, 2012).
Renn entered the securities industry in 2000 with Wells Fargo Advisor LLC‘s predecessor Wachovia Securities. From September 1, 2009, to January 6, 2012, Renn was employed as the Wells Fargo's Complex Operations Manager in Naples, FL. On January 13, 2012, a Uniform Termination Notice for Securities Industry Registration ("Form U5″) was filed and disclosed that Renn had been terminated on January 6, 2012. The AWC asserts that Renn has no previous disciplinary history.
As the Complex Operations Manager, Renn had numerous duties and obligations. He was responsible for supervising operations and the financial advisor assistants in the Fort Myers, Naples and Punta Gorda branch offices. In conjunction with the Complex Management Team, Renn was supposed to ensure proper execution of all operational, administrative and compliance functions. Additionally, Renn was to approve service requests for account updates, branch deposits and withdrawal, and escalated issues with clients and compliance for client accounts. In the event that the branches required the outlay of petty expenses, the firm had established a "Special Vending Account" in Renn's name.
On The Side
Alas, the AWC suggests that Renn could not resist the temptation of the small bills and loose change in the petty cash account. Allegedly, from August 16, 2011, to December 20, 2011, without the Firm's permission or authority, Renn journaled $2,250 from the "Special Vending Account" to his personal brokerage account. Not exactly the outlay for office supplies or soda for the vending machine that Wells Fargo likely had in mind when it established the account.
From there, things sort of went from bad to worse . . . or, if not worse then certainly oddball.
From September 1, 2011 to December 22, 2011, without the firm's permission or authority, Renn allegedly ordered printer ink cartridges, billed those purchases to Wells Fargo, and then re-sold the cartridges to a third-party vendor in exchange for some 16 wire transfers into his personal checking account for the total of $13,645.
FINRA deemed Renn's sticky fingered activities to constitute violations of FINRA Rule 2010, and, in accordance with the terms of the AWC, FINRA Barred Renn in all capacities with any FINRA firm.
Bill Singer's Comment
Over the years, I have frequently written about business expense cases. They hit at every level of Wall Street - at Goldman Sachs, Merrill Lynch, UBS, Morgan Stanley, JP Morgan, Wells Fargo. Sometimes it's a shlub who tried to get away with buying some Christmas presents while pretending they were business expenses. Sometimes it's a misguided hot-shot broker or trader who takes a few pals and clients to a strip joint. Sometimes it's a member of the C-suite who pays hundreds of thousands of dollars to decorate the office. And, yeah, sometimes it's helping yourself to petty cash and concocting an ink cartridge re-sale program.