Case In Point
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, Edward Thomas Hill submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Edward Thomas Hill, Respondent (AWC 2013036393901, August 7, 2014).
In 1992, Hill first became registered and, subsequently, from 1996 to June 1, 2009, he was registered with FINRA member firm Citigroup Global Markets lnc. ("CGMI"), and, thereafter, as part of a mass transfer of CGMI's personnel, he was registered with Morgan Stanley. On March 5, 2013, he was registered with Wells Fargo Advisors Financial Network, LLC. ("Wells Fargo").The AWC asserts that Hills had no prior relevant formal disciplinary history with the Securities and Exchange Commission, any self-regulatory organization or any state securities regulator.
The AWC alleges that in March 2013, Hill was preparing to depart Morgan Stanley for Wells Fargo, and, while still registered with Morgan Stanley, he removed from that firm's offices documents regarding approximately 46 customers. FINRA asserted that the documents contained nonpublic personal information, and were transported by Hill for storage at his home and, thereafter, placed in a locked personal storage facility.
The AWC deemed Hill's conduct as constituting violations of SEC Regulation S-P, Morgan Stanley's written supervisory procedures, and FINRA Rule 2010.
In accordance with the terms of the AWC, FINRA imposed upon Hill a Censure and a $5,000 fine.