An irreverent Wall Street Blog
by Bill Singer

2 Lies to FINRA Add Up to 1 Bar

June 4, 2018

With some folks, it just seems that their luck runs out. After a remarkable run beset with almost losing one's balance, almost falling down, almost getting hit by a falling something or other, almost not getting over an obstacle -- at some point, it ends short of the finish line. No prize. No trophy. Just another also-ran. In today's BrokeAndBroker.com Blog we look back on the career of one stockbroker who almost made it through the Wall Street obstacle course. Perhaps figuring he had several cat lives left, our contestant lied to FINRA and then lied to that regulator again. Not a smart idea the first time. Not a smart idea the second time. 

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, Christopher T. Wendel submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Christopher T. Wendel, Respondent (AWC  20170554768 01, June 1, 2018).

The AWC asserts that Wendel entered the industry in 1989 and by September 2014 was registered with FINRA member firm SA Stone Wealth Management Inc. The AWC asserts that "Wendel does not have any formal disciplinary history with the Securities and Exchange Commission, or any self-regulatory organization or any state securities regulator."

Promissory Notes

The AWC alleges that during the relevant period between April and August 2017 while he was associated with SA Stone, Wendel solicited investors to purchase promissory notes in Woodbridge Mortgage Investment Funds, a purported real-estate investment fund. Ultimately, Wendel allegedly sold $343,500 in Woodbridge promissory notes to four individuals for which he purportedly received over $10,000 in commissions. 

The AWC alleges that Wendel did not provide notice to and did not obtain approval from SA Stone prior to participating in what the AWC deemed to be private securities transactions ("PSTs") in violation of FINRA Rules 3280 and 2010. 



False Statements

The AWC alleges that in violation of FINRA Rules 8210 and 2010, that in:
  • January 2018, in response to a Rule 8210 request for information, Wendel provided a signed declaration falsely stating that his participation in the sale of a Woodbridge promissory note occurred after his association with SA Stone had ceased; and
  • March 2018, during his on-the-record testimony ("OTR"), Wendel falsely testified about the alleged post-association note sale. 

Discharge

Online FINRA BrokerCheck records as of June 4, 2018, disclose that S.A. Stone "discharged"  Wendel on September 5, 2017 based upon allegations the he "violated firm policy regarding selling away."

FINRA Sanctions

In accordance with the terms of the AWC, FINRA imposed upon Wendel a Bar in all capacities from association with any FINRA member. 

Bill Singer's Comment

There would seem to be at least two bedrock principles inherent in a registered person's interaction with any industry regulator. One, don't put anything in writing that's a lie. Two, don't say anything on the record that's a lie. A corollary to that second bedrock principle of regulatory interaction is that you should not testify falsely about any falsehood that you previously submitted in written form to a regulator and which also contains falsehoods.  


As to further context against which to form an opinion about Wendel, consider the following:

Settled Complaints

Online BrokerCheck records for Wendel as of June 4, 2018, disclose under the heading "Customer Dispute - Settled" that:
  • former employer WRP Investments  received a FINRA Arbitration Complaint on February 1, 2013, seeking $150,000 in damages based upon allegation that:
CLIENT ALLEGES THAT WENDEL INVESTED A LARGE PORTION OF THE CLIENT'S ASSETS INTO REIT THAT ARE CONSIDERED ILLIQUID AND THAT WENDEL SOLD LOW COST MUTUALFUNDS [sic] TO PURCHASE HIGHER COST MUTUAL FUNDS. CLIENT ALLEGES THAT THESE INVESTMENTS WERE UNSUITABLE FOR HIM BASED ON HIS OBJECTIVES.

WRP settled the matter on April 24, 2014, for $90,000 to which Wendel purportedly contributed the full amount.
  • former employer American Express Financial Advisors received a customer complaint on:
 July 3, 2003, seeking $49,107 in damages based upon allegation that:

THE CLIENT'S ATTORNEY HAS WRITTEN CLAIMING LOSSES DUE TO UNSUITABLE INVESTMENTS

American Express settled the matter on November 7, 2002, for $200,000 to which Wendel purportedly did not contribute. 

April 26, 2000, seeking $130,936.88 in damages based upon allegation that:

THE CLIENT ALLEGED I CONDUCTED UNAUTHORIZED TRADING, SIGNED OR OFFERED TO SIGN THE CLIENT'S SIGNATURE, CONVERT HER STOCK HOLDINGS FROM TYPE "A" TO TYPE "B" MUTUAL FUND SHARES TO HER DISADVANTAGE AND INVESTED IN ANNUITIES AGAINST HER WISHES DURING THE PERIOD OF FEBRUARY AND MARCH, THOUGH NOT IDENTIFIED BY THE CLIENT, DAMAGES ARE ESTIMATED TO EXCEED $5,000.

American Express settled the matter on November 150, 2000, for $130,936.88 to which Wendel purportedly contributed $8,350.00

Pending Complaints

Online BrokerCheck records for Wendel as of June 4, 2018, disclose under the heading "Customer Dispute - Pending" that S.A. Stone received a FINRA Arbitration Complaint on February 20, 2018, seeking $150,000 in damages based upon allegations of unsuitability and failure to supervise.

Closed Without Action Complaints
  • former employer WRP Investments, Inc received a customer complaint dated May 12, 2009, seeking $73,000 in damages based upon allegations:
CLINET'S [sic] SON ALLEGES THAT THE TRANSACTION IN THE LINCOLN NATIONAL VA WAS UNSUITABLE FOR HIS FATHER
  • former employer American Express Financial Advisors denied a customer complaint dated March 28, 2005, seeking $100,000 in damages based upon allegations:
THE CLIENT ALLEGES SHE WAS TOLD HER POLICY'S DEATH BENEFIT WOULD NEVER BE LESS THATN [sic] $250,000.00. SHE IS REQUESTING TO KNOW WHAT HER POLICY WILL BE WORTH UPON HER DEATH

Permalink

Search BrokeAndBroker

Related Topics

Previous Entries

Tag Cloud

Bill Singer BrokeAndBroker FINRA Arbitration AWC SEC BrokeAndBroker.com Expungement Employment Street Sweeper Bill SInger Jobs Wells Fargo Fraud OBA U5 Promissory Note U4 Email Wire Fraud UBS Elderly Forbes Merrill Lynch FBI Morgan Stanley Statutory Disqualification EFL PST Defamation ALJ Citigroup Suitability CRD Ponzi Borrowing Rule 3270 BrokerCheck Outside Business Activity OIP Whistleblower Guest Blog IRS Supervision Form U4 Bank Wachovia Felony DOJ Willful Wrongful Termination SDNY Mail Fraud Supreme Court Guest Blogger NAC Expenses IRA Discretion BrokerAndBroker Rule 2080 Ameriprise CCO Insider Trading Pro Se Form U5 Conversion Employment Tuesday Wife Checks Husband Madoff Punitive Damages Bankruptcy Rule 8210 OHO WSP Raymond James Rule 3040 Forgery Willfulness Rule 3240 Estate Credit Card NASD Dodd Frank Tax Settlement Frumento Discovery Rule 1122 Private Securities Transaction Rule 2010 Real Estate RIA Indictment LPL Commissions JP Morgan Outside Business Activities Wall Street Power of Attorney Business Expenses 2Cir Street Legal Bar Exam ATM BrokeAndBroker NYSE Annuities Impersonation Edward Jones Aegis Frumento Facebook Tax Lien Stephen Kohn Mortgage Rule 3280 Margin Bank of America Corrective Action Statement Antitrust Case In Point Small Firm Spouse Wire Tax Liens SRO Complaint Test Appeal Rule 2510 Schapiro Beneficiary ARS Offer of Settlement Schwab Employee Forgivable Loan Misdemeanor Trust NSF Goldman Sachs Due Diligence NASAA Signatures Promissory Notes ETF HFT T&P Securities Fraud Conspiracy Trustee VA Initial Decision Unauthorized Discretion Cease And Desist Loan Chase Annuity Lien Fidelity CFTC Signature POA Flash Crash OTR PCAOB Injunction RBC Deutsche Bank LOA Compliance Away Account DCCir Undisclosed Settlement Credit Cards Huffington Post Barclays NASDAQ Money Laundering Mandatory Arbitration Spouses email RRBDLAW.com MSSB Great Recession Continuing Education Unfair Competition Failure to Supervise Bonus Bharara Gallagher Scottrade Stay Registered Rep Magazine Variable Annuity Burris Lehman Brothers Insurance Liens Identity Theft Hacker Remand FINRA Arbitration Customer Reimbursement Options JPMorgan Rule 4511 Annual Compliance Questionnaire Audit Malware Solicitation Rule 12206 employment E*Trade Letter of Authorization Rule 3010 Stockbrokers Forex Wedbush Eligibility Rule Disclosure Fiduciary Rule 12805 brokeandbroker Registration BrokeAndBroker Bill Singer LIBOR Hacking TRO 2nd Circuit Customer Complaint Social Media Second Circuit Prison Solicited Net Capital Away Accounts Wey Will arbitration Rule 3050 jobs FINOP Retirement Website ACQ Dissent Unsuitability BOP BrokeandBroker Newman RMBS Time And Price Unsolicited Rule 4530 Unauthorized Trading Private Placement Bureau of Prisons Sanctions Broker Protocol 10Cir Motion to Dismiss Brummer Commission Private Securities Transactions Apple MetLife Trading Platform Reg SP Zipper Divorce Willfully Judgments Telephone BrokeAndBroker.com Blog Lehman OWB RRBDlaw.com Internet Deceased IC3 Plea Personal Expenses Variable Annuities FOREX China Marijuana Hedge Fund Protocol MC-400 Indemnification Confidential Information Rule 2150 Disgorgement Piwowar Spoofing Auction Rate Securities Obstruction of Justice WSPs Knight NYAG Stifel Emails Self Regulation ADA REIT Testimony DOL Rakoff Arbitraiton Crowdfunding FNMA Examination Lucia Rule 2111 Statute of Limitations Stifel Nicolaus Check Kiting Explained Decision Cheating Hilton Weiner Rule 12200 Dakota Securities Affiliate Waiver Debit Card Confidential Retaliation Gold Elder Abuse Hurry Appointments Clause Phishing Vacatur PNC Compensation Jurisdiction Woody Allen Securities Industry Commentator Churning Class Action Passcode Board SAC Sanction Guidelines Wine PN Due Process Aleynikov Khuzami Conflict Bandimere Morgan Keegan IPO Banc of America Postponement Ketchum MF Global Pennystock Executor Check Regulation SP Sexist Fees Raiding Medicare Bonds 9Cir Charge Rule 13805 Rosenthal Recruiting EIA Article V JOBS Act Joshua Brown Shah Gilani Lawyer Rule 2081 High Frequency Trading Botkin Reg D Wire Transfer Stanford Unjust Enrichment Affinity Fraud Discrimination bill singer OSHA OIG USERRA Marine Corps Sexism Finder\'s Fee White Imposter CEO Government Accountability Project Commodities Fraud 401k Private Placements Eligibility Membership Continuance SunTrust Consent Order Self Regulatory Organization Laptop McDuff Pennystocks TD Ameritrade Corzine Unregistered Charity Bid Rigging Chief Compliance Officer Oppenheimer ING Vietnam Mutual Fund Smith Barney Whitman Bank Fraud Ride the Thunder Concentration Deferred Compensation Embezzlement TOD Severance Marines Morgan Stanley Smith Barney Aguilar Termination TSSB Parking AML Small Firm Governor Online Series 7 Rule 3030 Statement of Corrective Action Mutual Funds Employment Agreement Restaurant Side Bar Accounting Teleconference Morgan Stanely Failure To Supervise Vault Whistleblowing Johnny Burris Information Yesenia Guitron Sales Assistant NPR Cannabis Written Supervisory Procedures Casino Dementia Puerto Rico Confirm 6th Circuit Mother Suspension Marketplace Disability Day Trading Loans Kon Statutory Disqualification Committee Bloomberg Bear Stearns Penson Guitron Testing Reg S-P Poteroba Hearing Rule 3110 Widow Customer Information CE Charles Schwab HSBC Corruption Tax Fraud Unauthorized Practice of Law Female Investor Alert PAQ Rule 9216 Inmate Scottsdale Judgment 40 Act Do Not Call Inability to Pay Elles Equity Indexed Annuities Stop Loss Escrow CPA Credit Suisse Argentina Stockbroker OWWP Dell 401(k) Thain Investment Adviser Stipulated Award Elder Law Rule 4513 Board of Governors Leveraged ETF Unsuitable Turnover OCIE Administrative Remedies Rule 9552 Over Concentration Florida FINRA AWC 4Cir Commissioner Stein TIC Department of Justice RRBDlaw Counterclaim Chase Investment Services Fowler Third Party Vendor Layering Congress ACH signature Probate Rule 2210 Arrest BD Sharemaster WaMu Feigenbaum Guest Bloggers Robert Cook Public Interest CNBC CGMI Red Flags Settling Away Joint Account SP Regulation FOCUS Outside Accounts Non-Solicitation Password Nietzsche Margin Call Rule 2370 Counterfeit Constitution Kiting Backstage Wall Street Client Information Form ADV IAR Money Market Star Wars Medical Condition Broke And Broker David Sobel Commodities Inside Information Lincoln Financial Moon Scholander Taft Correctional Institution Christian Stanley Reverse Life Insurance Schneiderman BATS Research Chiasson 11th Circuit Motion Fifth Amendment Wanger Trade Secrets Verbal Discretion Oral Discretion Rule 12504 Tortious Interference FCI Beaumont TheBlot Negligence expungement FCI Withdrawals Federal Reserve BrokerAndBroker.com Sexual Harassment Fine Outside Account Motion to Vacate CRS Timban Hospital Circuit Court Netschi Rule 1031 Moore Silver Collateral Bar Retroactive Bar MBS Boyland NRSRO Jennifer Tarr Cold Spring Advisory Group LLC Subpoena Newport Coast Securities Municipal Advisor Bill singer Merrill Resignation Turbeville FNI Media Evidence Merill Lynch Advisor Placement Group Goble Retroactive Rule 12212 NML NYG Capital SEC Rules of Practice Conflicts Bank Guarantee Springsteen Annual Audit McCartney Theft Trainee Fee 17a-5 Laser Outside Counsel In House Counsel Service 8210 FMLA Personal Information Martin Practice Sale BitTorrent BrokeAndbroker Varney Undercover BBVA Wages Liquidation Chevron Data Salman FINRA Board Obamacare Standing Rory Flynn Newbridge Scam Impersonator MSPB Relevant Bartko Office of Special Counsel Anderson Kennedy Reverse Merger Nasdaq US Airways Costa Rica Cellphone Johnson Mattera Grievance Lee Credit Repair Kierkegaard FTC JPM Attorneys\' Fees Permanent Bar Jon Corzine Meals Pension Elder Fraud Leveraged ETFs Collateral Securities and Exchange Commission Slander Apartment Reuters 9/11 Blockchain SIFMA Sharing Agreement Falsification Disciplinary History Texting Constructive Discharge Mistake 9th Circuit Statute of Limitation Excel false statements Privilege Obstruction Books and Records Checking Murray Kenneth Starr Short Sale Summary Judgment Compromise Wires Wire Transfers CD Trader Oilpro Kent Stock Promotion AXA FDA iPhone Supervisor Skimming Naskovets AAA CMO GAP Stephen A. Kohn ADR EDNY Dinner Wells Fargo Advisors Selling Away Koval Test Center Attorneys Fees Spoliation Sexual Discrimination AWC. FINRA Hugh Hewitt Lewis Carroll Subway Crypto Prime Bank FCPA Cybercrime God RRBDLAW House Financial Services Broy Electronic Communications Quasi Governmental Solomon Non Solicitation FINRA Small Firm Tippee Tipper Executrix PIABA Altered Records CDO Rule 420 NFA Fiduciary Duty Reform Lek Fee Books And Records Undertaking Risk Texas State Securities Board Sex Preet Bharara Enforcement Galleon SD Travel Payroll Immunity Funds Customers Brokeandbroker.com Sears Branch Manager Eric Stein Rules of Practice Chase Bank BrokeandBroker.com Mary Schapiro Criminal Countrywide Rule 13200 Initials Proctor Schumer Dow State Farm Willfull Expense Excessive Trading Taxes Nationwide DWI Gabelli AIG Reason for Termination Regulation S-P Walter BIll Singer Diabetes TCR Blank Forms Hertz Flash Drive BrokeAndBroke Puts Customer Files Merger Spam Exhaustion Doctrine Fiero SIPC 1Cir Manifest Disregard Finra Fines Expert Witness Bill Singer BrokeAndBroker Financial Disclosure 1099 Baby Boomers Pruco Compliance Officer Disparate Treatment Cherry Picking Lawyers Compliance Questionnaire Motion To Dismiss Coin Fourth Amendment Bribe Tran Google Janney Montgomery Scott S&P Martoma Non-Prosecution Agreement Ethics Retired Woman With Cane Mary Jo White Pacifico Promoter David Lerner Trading Death Father VXX Currency Molchatsky Tennis Court