January 8, 2014
What good is having a sales assistant if you can't send that lowly employee out for coffee, to pick-up your dry cleaning, or to sit and take some damn online exam for you, right? Human Resources and the regulators may not exactly share your somewhat outdated notions of demanding fealty from your serfs but, hey, there's only so much political correctness in a brokerage firm's branches.
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, Jason Goldstein submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Jason Goldstein, Respondent (AWC 2012033318101, December 11, 2013).
In 2006, Goldstein first became registered and during the relevant time from 2010 through July 7, 2012, he was registered with Deutsche Bank Securities Inc. ("DBSI"). The AWC asserts that Goldstein had no prior relevant disciplinary history with the Securities and Exchange Commission, FINRA, any other self-regulatory organization or any state securities regulator.
DBSI required its employees to complete annually an online training program in professional conduct. In May 2010, Goldstein was notified by email from DBSI that he was scheduled to complete certain on-line courses for DBSI's internal training program, among which was an annual professional conduct module, which he was required to personally complete. The AWC alleges that around May 14, 2010, Goldstein requested his sales assistant to take certain training courses for him and, in fact, facilitated that ruse by providing the assistant with his online password. Thereafter, in May and June 2010, the sales assistant logged onto DBSI's system posing as Goldstein and completed two courses.
The AWC asserts that Goldstein's misconduct constituted a failure to observe high standards of commercial honor and just and equitable principles of trade in violation of FINRA Rule 2010. In accordance with the terms of the AWC, FINRA imposed upon Goldstein a $5,000 fine and a 20-business-day suspension from association with any FINRA member firm in any and all capacities.
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