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Blank Customer Forms Can Blank Your Wall Street Career
Written: April 25, 2013

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, Respondent (Ed: registered person's name redacted by BrokeAndBroker.com Blog) submitted a Letter of Acceptance, Waiver and Consent (“AWC”), which FINRA accepted. (AWC 2012031027101, April 23, 2013

Respondent entered the securities industry in 1996 and was associated with Ameriprise Financial Services, Inc. from 1997 until his voluntary resignation on December 15, 2011. The AWC asserts that Respondent had no prior relevant disciplinary history.

During his association with Ameriprise, Respondent allegedly retained in his office files, twenty-nine blank or incomplete securities business-related documents, which had been previously signed by ten customers -- however, Ameriprise prohibited its representatives from obtaining or retaining documents that had been pre-signed by a customer. Among the cited documents were:
  • Switch Forms, 
  • Explanation of Transaction Forms, 
  • Disclosure Forms, 
  • Cash Distribution Forms, and 
  • Annuity Surrender Forms. 
A portion of the 29 blank documents were undated. and those bearing dates ranged from 2007 through 2010, with one document bearing a date from 2001.

FINRA deemed the above conduct to constitute violations of NASD Rule 2110 and FINRA Rule 2010. In accordance with the terms of the AWC, FINRA imposed upon Respondent a $5,000 fine and a 60-day suspension from association with any FINRA member in all capacities

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