An irreverent Wall Street Blog
by Bill Singer
 
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Written: October 21, 2014

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Oct 15Branch Financial Advisor - Severna Park,MD (197283)PNCSeverna Park, MD

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 15Financial Advisor - Perryville, MD (Cecil County) (197285)PNCPerryville, MD

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 12BRANCH FINANCIALADVISOR (196491)PNCIndianapolis, IN

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 11BRANCH FINANCIALADVISOR (194124)PNCNovi, MI

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Oct 10BRANCH FINANCIALADVISOR - Canton, OH (196300)PNCCanton, OH

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 08BRANCH FINANCIALADVISOR - Greater Toledo, OH area (193167)PNCToledo, OH

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Oct 08BRANCH FINANCIALADVISOR (195573)PNCDublin, OH

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Oct 08Branch Financial Advisor - St Clair Branch (196855)PNCPittsburgh, PA

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 08BRANCH FINANCIALADVISOR (195362)PNCAltamonte Springs, FL

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Oct 07BRANCH FINANCIALADVISOR (194128)PNCTroy, MI

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Oct 06Branch Financial Advisor(192956)PNCDuluth, GA

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 06Branch Financial Advisor(196555)PNCOrlando, FL

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 06BRANCH FINANCIALADVISOR - Chagrin Falls, OH (194238)PNCChagrin Falls, OH

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 06Financial Solutions AdvisorUSAASan Antonio, TX

seeking talented Licensed Financial Advisor for San Antonio call center. The ... PURPOSE OF JOB As a Financial Advisor, you will help to ensure the financial security of o... more

Oct 05BRANCH FINANCIALADVISOR (196088)PNCWooster, OH

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 05BRANCH FINANCIALADVISOR (194016)PNCDurham, NC

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 05BRANCH FINANCIALADVISOR (193968)PNCBoone, NC

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 03Branch Financial Advisor(161309)PNCSouthgate, MI

affluent marketplace. As a Branch Financial Advisor, you immediately become an important ... As a Branch Financial Advisor, your challenge is to cultivate and growfinancial planning... more

Oct 03BRANCH FINANCIALADVISOR (194522)PNCGurnee, IL

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 02BRANCH FINANCIALADVISOR (185553)PNCLouisville, KY

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 02BRANCH FINANCIALADVISOR (168801)PNCLa Grange Park, IL

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 02BRANCH FINANCIALADVISOR (165654)PNCSchaumburg, IL

in the affluent marketplace. As a Financial Advisor, you immediately become an important ... As a Financial Advisor, your challenge is to cultivate and grow financial planning relatio... more

Oct 19Financial ServicesRepresentative IFirst BankSaint Louis, MO

RMCC Job Title Financial Services Representative I Area of Interest Retail Banking Number ... In this role as a Financial Services Representative I your primary... more

Oct 19Financial ServiceRepresentatives NeededAmerican Wealth GroupSeattle, WA

transform middle America by securing their financial future and families! Job Description: We are an Independent marketing arm for Fidelity Life & Guaranty a New York Stock... more

Oct 19Financial ServicesRepresentativeNew York Life Insurance CompanyMyrtle Beach, SC

asset management and retirement plan services. Other New York Life affiliates ... array offinancial products and services to help clients develop a sound, long... more

Oct 18Financial Services Rep - Banker (Lee's Summit South)Bank of the WestLees Summit, MO

a European leader in global banking and financial services and one of the 6 strongest ... * Working knowledge of Bank's products and services. **Administrative/Technical Skills**...more

Oct 18Financial ServicesRepresentative I - North Wickham Rd.TD BankMelbourne, FL

**Job Description** The Financial Services Representative (FSR) acts as an ... with Disabilities. *Financial Services Representative I - North... more

Oct 18Service Center FinancialService RepresentativeTraineeScottradeWestminster, CO

Service Center Financial Service Representative Trainee - Westminster, CO Job ID: ... while training to become a licensed Financial Services Representativemore

Oct 17Financial ServicesRepresentative I (Trooper)TD BankNorristown, PA

visit www.td.com. **Job Description** The Financial Services Representative (FSR) acts ... with Disabilities. *Financial Services Representative I... more

Oct 16Financial ServicesRepresentativeInterra Credit UnionGoshen, IN

financial resource, identifying members’ financial needs and recommending solutions ... branches offering comprehensive financial planning and advisory services. Develops...more

Oct 15Financial ServicesRepresentatives - Licensedor Non-LicensedCornerstone StaffingDallas, TX

10 Financial Service Representatives. The Financial Service Representatives will take ... Job Title: Financial Service Rep (Licensed or Non-Licensed entry-level with... more

Oct 14Financial ServicesRepresentative- $60,000 - $100,000 PotentialNew York Life Insurance CompanyMelville, NY

Valuable exposure to the exciting financial services industry A stimulating ... andFinancial Services Professional A licensed financial services professional is... more

Oct 13Financial Service Rep - AcquisitionFifth Third BankLawrenceville, GA

responsibilities, working with the Customer Services Manager, to maintain the efficient ... of more specialized bank products and services to customers, so thatpersonal and... more

Oct 13Financial ServicesRepresentative/ AgentNew York LifeEvansville, IN

provides: Valuable exposure to the exciting financial services industry A stimulating ... andFinancial Services Professional A licensed financial services professional is... more

Oct 08Customer Service Representative/FinanceCity of NaplesNaples, FL

GENERAL DESCRIPTION OF DUTIES: The purpose of the position is to perform routine to moderately complex account maintenance and customer service work for the City’s utility...more

Oct 07Associate Financial ServiceRepresentativeE*TRADE FinancialSandy, UT

SUMMARY_****: As an **Associate** **Financial Services Representative,**this ... and goals. * An Associate Financial Services Representative will perform... more

Oct 06Licensed Financial ServicesRepresentativeAllstate FinancialRepJackson, MS

As an Allstate Personal Financial Representative you'll soar to new heights ... more becoming an Allstate Personal Financial Representative. More About Allstate The... more

Oct 01Insurance Representative -Financial Services SalesWestern and Southern LifeDaytona Beach, FL

Washington Investment Advisors, Inc.1; IFS Financial Services, Inc.; Peppertree Partners ... Financial Services, Inc.; Peppertree Partners LLC;1 Touchstone Advisors, Inc.;1 Touchstone... more

Oct 20JPMorgan Securities | Client Associate |JPMorgan ChaseSan Francisco, CA

, with a high degree of accuracy, in a high pressure environment. Highly proficient user of Word, PowerPoint and Excel JPMorgan Chase is an Equal Opportunity and Affirmative...more

Oct 18JPMorgan Chase Institute Deputy - Project Manager- Executive DirectorJPMorgan ChaseWashington, DC

results on major projects/programs JPMorgan Chase is an equal opportunity and ... *CORPORATE SECTOR* **Title:** *JPMorgan Chase Institute Deputy - Project... more

Oct 14JPMorgan Securities | Marketing Assistant |JPMorgan ChaseAtlanta, GA

role. * Bachelor's degree required. JPMorgan Chase offers an exceptional benefits program ... competitive compensation package. JPMorgan Chase is an Equal Opportunity and Affirmative... more

Oct 14JPMorgan Securities | Administrative Assistant |JPMorgan ChaseNew York City, NY

skills JPMorgan Chase offers an exceptional benefits program and a highly ... compensation package. JPMorgan Chase is an Equal Opportunity and Affirmative Action... more

Oct 13Jpmorgan Securities | Administrative Assistant |JP Morgan ChaseCompanyNew York City, NY

follow-up and follow-through skills JPMorgan Chase offers an exceptional benefits ...JPMorgan Chase is an Equal Opportunity and Affirmative Action Employer, M/F/D/V... more

Oct 11Global Sales Director, Pan-HP - JPMorgan ChaseHPPalo Alto, CA

versees engagements with multiple portfolio solutions. **Job** *Sales* **Title:** *Global Sales Director, Pan-HP - JPMorgan Chase* **Location:** *United States* **Requisition...more

Oct 21Corporate Compliance Specialist III, Compliance Testing (TDAF)TD BankFarmington, MI

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 20Credit Analyst II/Healthcare/Mercerville, NJ (Quakerbridge)TD BankTrenton, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 20Business Systems Analyst IITD BankFalmouth, ME

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 20Retail Loan Review Portfolio Monitoring ManagerTD BankSouth Portland, ME

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 18Corporate Compliance Manager - TDAFTD BankFarmington, MI

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 18Teller I - 40hrsTD BankConcord, MA

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 18Credit Analyst IITD BankBurlington, VT

Personal and Commercial Banking - including TD Canada Trust and TD Insurance Wealth ...TD Waterhouse and an investment in TD Ameritrade U.S. Personal and Commercial... more

Oct 18AML QA Analyst II - AML QA OpsTD BankMount Laurel, NJ

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 17Mortgage Loan Processor - Mortgage SettlementTD BankLewiston, ME

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 17AML Investigator I - EDDOTD BankLexington, SC

Banking - including TD Canada Trust and TD Insurance * Wealth Management - including ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 17Corporate Compliance Specialist III, Compliance Testing (TDATD BankFarmington, MI

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 17Business Systems Analyst II, Corp Sys Service DeliveryTD BankFalmouth, ME

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 17US Capital Management Group - Governance and Controls ManageTD BankMount Laurel, NJ

Personal and Commercial Banking - including TD Canada Trust and TD Insurance * Wealth ...TD Waterhouse and an investment in TD Ameritrade * U.S. Personal and Commercial...more

Oct 08Desktop Support Representative (103946)TD AmeritradeFort Worth, TX

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 06Senior Java Developer (103938)TD AmeritradeColumbia, MD

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 03Analyst Sr Lean COE (103922)TD AmeritradeSan Diego, CA

* PMP certification (preferred) TD Ameritrade participates in the E-Verify ... TDAmeritrade is a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 03Branch Manager Oakbrook IL (103920)TD AmeritradeChicago, IL

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Investment Consultant 6th Avenue NY NY (103902)TD AmeritradeNew York City, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Senior Engineering Consultant (103862)TD AmeritradeColumbia, MD

infrastructure requirements and standards TD Ameritrade participates in the E-Verify ... TDAmeritrade is a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Bank Consultant New York NY (103907)TD AmeritradeNew York City, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 02Senior Manager Database Administration (103863)TD AmeritradeOmaha, NE

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Oct 02Bank Consultant Flushing NY (103904)TD AmeritradeQueens, NY

investors to sophisticated traders, TD Ameritrade is focused on helping ... TD Ameritradeis a trademark jointly owned by TD Ameritrade IP Company and the Toronto-Dom... more

Oct 10Compliance Analyst, Office of General CounselFinancial Industry Regulatory Authority (finra)Washington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Compliance Analyst opening with our...more

Oct 09Compliance Examiner, Member RegulationFinancial Industry Regulatory Authority (finra)New Orleans, LA

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Compliance Examiner opening in New Orleans, LA. To be considered for this... more

Oct 09Regulatory Analyst - OFDMI-Fraud - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Regulatory Analyst - Fraud opening in Rockville, MD. To be considered for this... more

Oct 08Regulatory Analyst - Market Regulation, Trading Analysis - Rockville,Md.Financial Industry Regulatory Authority (finra)Atlanta, GA

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Regulatory Analyst opening in Rockville, Md. To be considered for this position,... more

Oct 07Undergraduate Intern - Internal Audit - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

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Oct 07Undergraduate Intern - Finance - Rockville, MD.Financial Industry Regulatory Authority (finra)Riverdale, IL

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Oct 04Senior Technology Manager - Rockville, MD orFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Senior Technology Manager opening in Rockville, MD or New York, NY. To be... more

Oct 01Compliance Examiner, Member Regulation Sales PracticeFinancial Industry Regulatory Authority (finra)San Francisco, CA

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Compliance Examiner opening in San Francisco, CA. To be considered for this... more

Oct 20Director-Shared Sevices Engineering & Operations,Technology, RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director, Shared Services... more

Oct 20Regulatory Analyst, (Contractor) Options RegulationFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Regulatory Analyst opening in New York, NY. To be considered for this position,... more

Oct 20Director-Technology Development, RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Director, Shared Services... more

Oct 20Corporate Controller FINRAAppian StaffingTampa, FL

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Oct 18Stockbrokers/Broker TraineesNew York Brokerage FirmWestbury, NY

Job Description: We are currently searching for hardworking and self motivated individuals to join our newly expanded office. The role of trainee will allow the individual to work... more

Oct 17Research Analyst III, Regulatory ProgramsFinancial Industry Regulatory Authority (finra)Washington, DC

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Research Analyst opening in... more

Oct 17Regulatory Analyst - OFDMI/ Office of Whistleblower - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Regulatory Analyst opening in... more

Oct 16Associate Developer in Test - Technology - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. The Financial Industry Regulatory Authority (FINRA) is seeking a well-qualified individual for our Associate Developer in Test opening...more

Oct 16Technology Supervisor - Rockville, MD - Contractor ConversionFinancial Industry Regulatory Authority (finra)New York City, NY

We Work to Protect Investors. Join our Team. FINRA is seeking a well qualified individual for our Technology Supervisor opening in New York, NY. To be considered for this... more

Oct 14Regulatory Analyst - Market Regulation-Market Manipulation Investigations - RockvilleFinancial Industry Regulatory Authority (finra)Potomac, MD

We Work to Protect Investors. Join our Team. FINRA is seeking a well-qualified individual for our Regulatory Analyst opening in Rockville, MD. To be considered for this position,... more

Oct 09Service Center StockbrokerScottradeWestminster, CO

Service Center Stockbroker - Westminster, CO Job ID: 20141507-9337 Description: Scottrade is seeking an energetic, career-minded professional to join our award-winning financial... more

Oct 08Stockbroker, Series 7, National Firm - High Payout Will Train!Joseph Stone CapitalMineola, NY

Job Description: Stock Brokers Wanted (Will Train) Come work at the headquarters of an established national broker-dealer that caters to producing brokers. We are looking for...more

Oct 07StockbrokerRothschild LiebermanNew York City, NY

New York Broker Dealer with a 40 year history of success located in the heart of the financial district is currently seeking Stockbrokers who have their own books of business with... more

Oct 06Registered Investment Office Manager - Series 7 & 63 FINRA registrations requiredFuturity FirstScottsdale, AZ

This position reports directly to the Branch Manager of a FUTURITY FIRST (FFIG) branch office with a matrix reporting relationship with the Home Office Director, Operations. more

Oct 04Stockbroker/Financial AdvisorForte Capital GroupNew York City, NY

Company Description: Forte Capital is a full service, independent, brokerage firm located in the heart of the Financial District. We are small enough to give clients the... more

Oct 02Financial Operations Examiner – Market Regulation, Trading & Financial Compliance Examinations - Chicago, IL(Job Number: 003676)FinraChicago, IL

Description Title: Financial Operations Examiner Department: Market Regulation, Trade Exams & Special Reviews Location: Chicago, IL Grade: 43-46 We Work to Protect Investors. Join... more

Oct 02Consolidated Supervised Entity Examiner - Member Regulation, ROOR - New York, NY(Job Number: 003452)FinraNew York City, NY

Job Summary : The Examiner conducts assignments on routine and special Consolidated Supervised Entity (CSE) examinations to assess member firms' risk management framework and... more

Oct 02Regulatory Coordinator - Member Regulation, Sales Practice - New York, NY(Job Number: 003573)FinraNew York City, NY

Description Relocation assistance is available for exempt internal employees (lump sum allowance only). Exceptions to receiving a lump sum allowance require approval; contact your... more

Oct 02Compliance Examiner - Market Regulation, Trading & Financial Compliance Examinations (TFCE) Options- New York, NY(Job Number: 003500)FinraNew York City, NY

Description Title: Compliance Examiner Department: Market Regulation, Trade Exams & Special Reviews Options Location: New York, NY Grade: 43-46 We Work to Protect Investors. Join... more

Oct 02Financial Operations Examiner - Member Regulation, ROOR - New York, NY(Job Number: 002996)FinraNew York City, NY

We Work to Protect Investors. Join our Team. Job Summary : Conduct on-site examinations and assess member organization's financial and operational condition and compliance with...more

Oct 02Senior StockbrokerArjentNew York City, NY

Company Description: Arjent a leading boutique Investment firm based In Manhattan, New York offering a full service brokerage to Institutions and HNW Private Clients has an... more

Oct 02Compliance Examiner, Member Regulation Sales Practice - San Francisco, CA(Job Number: 003691)FinraSan Francisco, CA

Description Title: Examiner (Future Openings) Department: Member Regulation - Sales Practice Location: San Francisco District Office Grade: 43 to 47 Note: This is a Pipeline...more


 

Written: October 20, 2014

Once upon a time, Wall Street's regulators seemed to view so-called "Failure To Supervise" matters as a last resort -- the final arrow in a quiver.  Whether benign neglect or a considered policy, those supervising the industry's stockbrokers and traders often erred on the side of caution when it came to reprimanding a top producer. As a result, a lot of what passed for supervision was fairly reminiscent of somnambulism. In the past few years, however, those folks who persist in sleepwalking through their compliance obligations have had a rude awakening before a host of unhappy regulators all too ready to fine and suspend them. Frankly, it's an overdue change in priorities and one that is necessary. Consider this recent case.

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, Roger S. Rathmell submitted a Letter of Acceptance, Waiver and Consent (“AWC”), which FINRA accepted. In the Matter of Roger S. Rathmell, Respondent (AWC 2013037137601, October 2, 2014).

In 1971, Rathmell entered the securities industry and first became registered in 1980 with Merrill Lynch, Pierce, Fenner & Smith Inc. The AWC asserts that he had no prior disciplinary history.

The Telephone Call

On October 26, 2011, at a time when Rathmell was an Administrative Manager of several Merrill Lynch branch offices, he received a telephone call from a customer, who complained that registered representative Greg Campbell had engaged in unauthorized activity in the customer’s IRA and personal brokerage accounts. On that same day and after the call, the customer sent an email to Rathmell describing the unauthorized activity – and asserting that loans had been taken in his name using his securities as collateral; and that his address of record was changed.

Merrill Lynch's policies and procedures required that Rathmell, who supervised Campbell, report this customer's complaint via the firm’s computerized system within three days of receipt. The AWC alleges that Rathmell failed to timely file the required report.

In Case You Were Wondering

Following Campbell’s October 29, 2011, departure, Merrill Lynch filed a Uniform Termination Notice for Securities Industry Registration ("Form U5") that stated the termination was “Voluntary,” and did not reference any customer complaints.

A Tick-Tock SIDE BAR: In case you didn't catch the operative dates, the customer complaint came in on October 26th and Campbell headed for the door on October 29th. The lag-time between those two events was three days -- the exact time span in which Rathmell was supposed to enter into Merrill Lynch's computer system his report of the customer's complaint.  Whether Campbell gamed the clock or whether Rathmell believed that the registered rep's resignation pre-empted the need to file the report is not discussed in the AWC.

Second Complaint (After Campbell Left)

About seven months after Campbell's departure from Merrill Lynch, Rathmell received a written complaint on May 25, 2012, from another of Campbell’s customers alleging unauthorized withdrawals and loans.  Additionally, this customer alleged that he had not been receiving account statements. The AWC asserts that again failed to timely report this second customer complaint.

The AWC asserts that as a result of Rathmell’s untimely disclosures of the customer complaints, his employer Merrill Lynch did not report the allegations to FINRA until October 26, 2012, in violation of FINRA Rule 4530(a)’s requirement of timely reporting within 30 calendar days of notice.

A Costly Failure

Online FINRA records as of October 9, 2014, assert that Merrill Lynch “Discharged” Rathmell on October 17, 2012 based upon allegations of:

FAILURE TO TIMELY ELEVATE A COMPLIANCE MATTER AND TO REPORT CLIENT COMPLAINTS

By failing to promptly report the two written customer complaints to appropriate Firm personnel, Rathmell violated FINRA Rules 4530(c) and 2010. In accordance with the terms of the AWC, FINRA imposed upon Rathmell a $10,000 fine and a six-month suspension in any capacity from association with any FINRA member firm.

Bill Singer's Comment

No big deal, you may say. Rathmell maybe didn't recognize the need to file an in-house notice about two customer complaints, you might add. Anyway, Campbell left three days after the first complaint and was gone for some seven months by the time the second customer complained -- geez, Bill, cut Rathmell some slack. Two isolated customer complaints and one didn't even involve a current employee under Rathmell's supervision.

Now, do me a favor, consider these additional facts:

From May 2008 to October 2011, Merrill Lynch Registered Representative Greg Campbell misappropriated over $1.7 million in customers’ funds; and, after leaving the Merrill Lynch, he tacked on another $500,000 in misappropriations at his new firm.  Although not identified in the Rathmell AWC, online FINRA records disclose that Campbell was registered with LPL Financial LLC from October 28, 2011, until his termination on October 31, 2012, when LPL discovered he had been misappropriating customers’ funds. Those FINRA records disclose that:

From May 2008 through October 2012, Campbell misappropriated over $2 million in funds from customers at Merrill Lynch and LPL, including elderly customers and members of Campbell's family. Most of the misappropriated funds were converted by Campbell for his personal use; some of the misappropriated funds were transferred between customers' accounts to replace converted funds. Campbell's conduct violated FINRA Rules 2150 and 2010 and NASD Rules 2330 and 2110.

FINRA imposed upon Campbell an industry Bar. In the Matter of Greg J. Campbell, Respondent (AWC 2012034193201, March 15, 2013).

Although the Rathmel AWC  may get lost in the shuffle as a somewhat mundane failure-to-supervise case, in fact, in-house supervision (so-called "Compliance") is an important component of Wall Street's self-policing. The consequences of sleepwalking through your duties or not timely reporting problems can have devastating consequences. If -- and I grant you that it's a big if --- Rathmell had timely submitted his in-house report about the October 26, 2011, customer complaint, that complaint may have -- and, yeah, that "may" is another big may -- been included on Campbell's FormU5. If the October 26, 2011, customer complaint was disclosed on Campbell's Form U5, then LPL may have -- and, here we go again with a second "may" that proved to be another big "may" --  investigated Campbell's background and been more attentive to his conduct during his post-October 29, 2011, tenure with LPL.  

Why do I make such a big deal about those ifs and mays? FINRA asserted that Campbell ripped off his LPL customers to the tune of  $500,000 (which was in addition to the $1.2 million he had previously misappropriated from Merrill Lynch customers. Making the consequences even worse, consider the circumstances of one of the customers defrauded by Campbell (as set forth in the Campbell AWC):

Customer HK is 85 years old and currently suffers from dementia. He opened a brokerage account with Campbell in July 2006. Campbell opened an LMA for HK in March 2009 without HK's knowledge or consent. From August 2009 through October 2011, Campbell converted over $930,000 from HK's LMA to an account at JPMorgan Chase Bank servicing a home-equity line of credit maintained by Campbell. In addition, Campbell effectuated unauthorized transfers totaling over $112,000 from HK's LMA to the LMA of Customer PC.  To conceal his activities, Campbell had HK's account statements delivered "care of Customer PC, who is of no relation to HK.

 

Written: October 18, 2014

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FINRA SOUTH REGION SMALL FIRM ADVISORY BOARD ("SFAB") ELECTION
FINRA small firm members in the South Region have three candidates available for election to the SFAB by Friday, November 14, 2014.  Of the three nominees, I wholeheartedly endorse Carrie Wisiniewski, President, Bridge Capital Associates, Inc. and urge all eligible firms to vote for her.  Bill Singer

 

 
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