An irreverent Wall Street Blog
by Bill Singer
 
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Written: January 28, 2015

Another day and another email disaster at another major FINRA member firm. In the end, however, the customer is made a whole -- but the registered person is made a bit less than whole by a fine and suspension.  Some good lessons embedded in this regulatory settlement. 

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, Michael Vincent Borja submitted a Letter of Acceptance, Waiver and Consent (“AWC”), which FINRA accepted. In the Matter of Michael Vincent Borja, Respondent (AWC  #2013037029901, January 21, 2015).

In 2008, Borja entered the securities industry with FINRA member firm UBS International Inc.; thereafter, he was registered with Oppenheimer & Co. Inc from 2009 to January 2012; and then with Wells Fargo Advisors, LLC. until his May 2013 discharge. The AWC asserts that for about two weeks in July 2013, he was also employed in a non-registered capcity with VALIC Financial Advisors, Inc. The AWC asserts that Borja had no prior formal disciplinary history in the securities industry.

Registered Service Associate

Upon the inception of his employment with Wells Fargo Advisors, Borja was a registered client service associate and assigned to a stockbroker described only as “MT” in the AWC. Among Borja’s duties were to open new accounts, handle trades, and process wire transfers. One of stockbroker MT’s customers, described only as “GS” in the AWC, was serviced by Borja from the beginning of his employment.

November 6, 2012 Email

On November 6, 2012, Borja received an email from customer GS with an attached Letter of Authorization (“LOA”) requesting the transfer of $18,971 from the customer’s brokerage account to a third-party account in Lima, Peru. As it turned out, the email was not sent by customer GS but by an imposter.

Unlike many of these cases, the AWC advises us that the “email address was not one known to be associated with the customer, but contained the customer’s name in the email address.” 

Under such circumstances, it would appear that the sender’s use of a previously unknown address might have alerted Borja and others to be wary – or at least make sure to follow the firm’s protocols for handling such email requests. In fact, the AWC asserts that Borja did not call the customer to confirm the wire request but merely processed the transfer. Worse, the AWC alleges that Borja 

falsely claimed that he had spoken with GS, that he knows him personally and recognized GS's voice. Borja falsely entered “pmt to friend for personal loan" in the Service Request as the intended purpose for the wire.

December 5, 2012 Email

On December 5, 2012, received a second email from an imposter with attached LOA seeking a transfer of an additional $48,561 to the Lima account. It is unclear from the AWC whether this second email came from the same imposter as the November 6th communication. The AWC explains that “[t]his email was a variation of the email address used in the November 6, 2012 request and was also not an email address associated with the customer."

In response to this second transfer request, Borja again did not call the customer to confirm and he went ahead and processed the wire and also offered the same false assurances to his firm concerning his efforts at verification. 

Not How We Wanted It Done

During all times relevant to this matter, Wells Fargo’s written supervisory procedures purportedly required, among other things, that upon receipt of a wire request seeking to transfer to a non-customer, an associate was supposed to prepare a Service Request setting forth various details and disclosures. Pointedly, the AWC asserts that:

For all outgoing wire requests in excess of $10,000, associates must personally speak with the customer, confirm the wire instructions and document the wire instructions and verification of the customer's identity in the Service Request. When accepting verbal instructions from customers, the associates must verify the customer's identity either through knowing the customer personally and recognizing his or her voice or by obtaining at least two pieces of personally identifying information. These can include a Social Security or Tax Identification Number, date of birth, home telephone number, or recent account activity. The associate must document the customer's name, who received the instructions, when the instructions were received, and how the identity of the customer was verified. . .

Made Whole

Upon discovery of the fraud, Wells Fargo fully reimbursed customer GS for the two transfers. 

Made Less Than Whole

Online FINRA BrokerCheck records as of January 25, 2015, disclose that Borja was 
“Discharged” by Wells Fargo Advisors on May 3, 2013, based upon allegations that:

MR. BORJA ENTERED CERTAIN INFORMATION ON THE FIRM’S SYSTEMS THAT WAS INCORRECT WITH RESPECT TO CLIENT ACCOUNT UPDATES, AND PROVIDED CERTAIN INFORMATION REGARDING COMPLIANCE WITH FIRM POLICY IN CONNECTION WITH A WIRE TRANSFER THAT WAS NOT ACCURATE

FINRA alleged that Borja’s false attestations and submission of false information violated FINRA Rule 2010; and that his conduct further caused his firm to maintain false books and records in violation of FINRA Rules 4511 and 2010. 

In accordance with the terms of the AWC, FINRA imposed upon Borja a $5,000 fine and a suspension of 45 calendar days from associating with any FINRA-regulated broker-dealer in any capacity. 

Bill Singer's Comment

At times I am sympathetic to the often-lowly employees who seem sacrificed by their employer firms when it comes to some of these hacked/imposter email requests for wire transfers. In this case, however, FINRA got it right and I applaud the regulator's efforts and moderate sanctions. The AWC offers compliance professionals several excellent insights and tips that may suggest "best practices" for member firms. The one quibble I will note is that Wells Fargo fired Borja in May 2013 but it took FINRA about 20 months to settle this case. Truly, this type of matter should be settled or charged on a more aggressive basis.


 

Written: January 27, 2015

Seems to me that Wall Street is quite a bit like weather forecasts. Take today, for example -- in NYC, we were supposed to awake to Snowmageddon with close to three feet of snow and a howlin' storm. There wasn't much doubt according to all those fine folks online, on TV, and on the radio. It's comin'. Get inside! They pointed to their charts and computer projections. They said it was all based on cutting-edge science. 

Well, guess what? It ain't all that bad out there. Sure, there's about a foot of snow, if that, and, yeah, it's freezing; however, we never quite approached the end of the world. 

Which takes me back to my point about the weather forecasting and Wall Street. Greece voted in some leftist government. The Russians are still sending tourists to the Crimea and Ukraine but they are oddly carrying RPGs and Kalyshnikovs. Gas is dropping. Oil is dropping. The death of the Euro is nigh. And a lot of folks are again predicting the mother-of-all stock market crashes -- as they have predicted 11 of the last 3 bear markets.

I dunno about you but I'm getting ready to drink a vat of coffee and munch through several boxes of cookies that I bought in order to get me through Snowmaggedon. If you too are house-bound, I thought you might enjoy a few stormy tunes. Afterwards, you can peruse some of the BrokeAndBrroker.com Blog Employment Page job listing.

"The Storm" by Tedeschi Trucks Band


"Stormy Monday" by Cream


"Shelter From The Storm" by Bob Dylan


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Topics: BrokeAndBroker  Bill Siner  
 

Written: January 26, 2015

Imagine that you're broke and can't afford a fabulous but high-priced regulatory lawyer like me and you need to submit a brief in response to some absolutely outrageous allegations made against you by the Securities and Exchange Commission ("SEC"). The first step you should take is to read -- quite carefully -- the exact SEC Rule of Practice that governs how a brief is to be prepared and submitted.  You didn't know that the rules got so nitty gritty? Yeah, they get highly focused. In any event, take a few minutes and read the following Rule. There will not be any pop quiz at the end of this exercise, so, just take your time and enjoy the amazing world of legalese:

Rule 450. Briefs Filed with the Commission.

(a) Briefing Schedule Order. Other than review ordered pursuant to Rule 431, if review of a determination is mandated by statute, rule, or judicial order or the Commission determines to grant review as a matter of discretion, the Commission shall issue a briefing schedule order directing the party or parties to file opening briefs and specifying particular issues, if any, as to which briefing should be limited or directed. Unless otherwise provided, opening briefs shall be filed within 30 days of the date of the briefing schedule order. Opposition briefs shall be filed within 30 days after the date opening briefs are due. Reply briefs shall be filed within 14 days after the date opposition briefs are due. No briefs in addition to those specified in the briefing schedule order may be filed except with leave of the Commission. The briefing schedule order shall be issued:

(1) at the time the Commission orders review on its own initiative pursuant to Rules 411 or 421, or orders interlocutory review on its own motion pursuant to Rule 400(a); or

(2) within 21 days, or such longer time as provided by the Commission, after: (i) the last day permitted for filing a petition for review pursuant to Rule 410(b) or a brief in opposition to a petition for review pursuant to Rule 410(d);

(ii) receipt by the Commission of an index to the record of a determination of a self-regulatory organization filed pursuant to Rule 420(d);

(iii) receipt by the Commission of an index to the record of a  determination by the Board filed pursuant to Rule 440(d);

(iv) receipt by the Commission of the mandate of a court of appeals with respect to a judicial remand; or

(v) certification of a ruling for interlocutory review pursuant to Rule 400(c).

(b) Contents of Briefs. Briefs shall be confined to the particular matters at issue. Each exception to the findings or conclusions being reviewed shall be stated succinctly. Exceptions shall be supported by citation to the relevant portions of the record, including references to the specific pages relied upon, and by concise argument including citation of such statutes, decisions and other authorities as may be relevant. If the exception relates to the admission or exclusion of evidence, the substance of the evidence admitted or excluded shall be set forth in the brief, in an appendix thereto, or by citation to the record. Reply briefs shall be confined to matters in opposition briefs of other parties.

(c) Length Limitation. Except with leave of the Commission, opening and opposition briefs shall not exceed 14,000 words and reply briefs shall not exceed 7,000 words, exclusive of pages containing the table of contents, table of authorities, and any addendum that consists solely of copies of applicable cases, pertinent legislative provisions or rules, and exhibits. The number of words shall include pleadings incorporated by reference. Motions to file briefs in excess of these limitations are disfavored.

(d) Certificate of Compliance. An opening or opposition brief that does not exceed 30 pages in length, exclusive of pages containing the table of contents, table of authorities, and any addendum that consists solely of copies of applicable cases, pertinent legislative provisions, or rules and exhibits, but inclusive of pleadings incorporated by reference, is presumptively considered to contain no more than 14,000 words. A reply brief that does not exceed 15 pages in length, exclusive of pages containing the table of contents, table of authorities, and any addendum that consists solely of copies of applicable cases, pertinent legislative provisions, or rules and exhibits, but inclusive of pleadings incorporated by reference, is presumptively considered to contain no more than 7,000 words. Any brief that exceeds these page limits must include a certificate by the party's representative, or an unrepresented party, stating that the brief complies with the length limitation set forth in Rule 450(c) and stating the number of words in the brief. The person preparing the certificate may rely on the word count of the word-processing system used to prepare the brief

WTF, you say?  Well, now you know why I get the big bucks. If you found yourself sobbing uncontrollably as you tried to figure out the "when, what, and how" of the filing rules, don't feel too bad about it: welcome to my world!  Here . . . take a tissue, wipe your eyes.

You're Gonna Have To Serve Somebody (With A Proper Brief)

Now that you are an expert and fully familiar with the SEC’s rule about how to submit a brief, let’s consider the mess that has arisen in this case: In the Matter of John Thomas Capital Management Group Llc D/B/A Patriot28 LLLC and George R. Jarkesy, Jr. (Order Directing Additional Submission, Securities and Exchange Commission, ’33 Act Release No. 97 03; ’34 Act Release No. 74100; ’40 Act IA Act Release No. 4002;  ’40 Act IC Act Release No.; and Admin. Proc. File No. 3-15255 / January 20, 2015

A Consolidated Opening Brief

On January 13, 2015, Respondents John Thomas Capital and Jarkesy, Jr. filed their consolidated opening brief in the above SEC proceeding. It seems that the SEC wasn’t quite happy with the format and content of that submission and in a somewhat unusual move – a reprimand, of sorts – the Respondents have been referred to SEC Rule of Practice 450(b). You'll note that I have conveniently highlighted that section in an ever-popular hue of yellow. Pointedly, the SEC notes that:

It appears that the sections of the opening brief enumerating respondents' exceptions to the initial decision's evidentiary rulings (Br. at 36-38), factual findings (id. at 39-45), and legal conclusions (id. at 46-47) do not contain any citations to portions of the record or to legal authorities. For example, the discussion accompanying each of the challenged factual findings consists essentially of the boilerplate assertion that the finding in question mischaracterizes the evidence, relies on unreliable evidence, and ignores contradictory evidence. In each instance, the only citation provided is to the page of the initial decision that recites that finding; no reference is made to the "relevant portions of the record, including . . . the specific pages relied upon" by respondents, as required by Rule 450(b). The discussion accompanying each of the challenged legal conclusions is just as conclusory: It repeatedly asserts that the law judge mischaracterized the evidence, ignored contrary evidence, and misapplied the law, but without a single citation to record evidence or to any statute, regulation, or court or Commission decision.

Accordingly, it is

ORDERED that respondents shall, by no later than February 3, 2015, file a submission setting forth, in a two-column format, the citations supporting each of the exceptions asserted in pages 36 to 47 of their opening brief. The first column shall reproduce verbatim each exception as stated in the opening brief. The second column shall contain citations, without discussion or commentary, to "relevant portions of the record, including references to the specific pages relied upon," and relevant "statutes, decisions, and other authorities" supporting that exception.10 The citations shall identify precisely—i.e., by page or Bates number or other similar designation—where the information can be found in the referenced materials and may, if respondents choose,be accompanied by parentheticals with pertinent quotations.

It is further ORDERED that the submission be accompanied by a certificate stating the total number of words in the second column of the submission.

Bill Singer's Comment

Howsabout a quick review?

According to Rule 450(b), there are limits and restrictions on what can't be included and what must be included in a Brief.

We start with the initial premise that the Brief must be "confined to the particular matters at issue." That's nice but, geez, what happens when a respondent thinks that the "particular matters" are much wider or more narrow than what the SEC Staff thinks? 

Leaving the realm of "particular," we then arrive on the shores of "succinctly," where you are admonished that any exception you may have to the SEC's findings/conclusions, must be stated "succinctly."  My, my, my . . . and pray, tell me, how does one define succinctly?

Our trailblazing takes us into even deeper woods, where Rule 450(b) warns that any exceptions you plan on noting must be made via a "concise argument" replete with relevant citations. Okay, so tell me, the difference between a "concise argument" and just a plain argument is what?

Say what you will. Think what you want. What is indisputable is that the Respondents in John Thomas Capital Mgmt either didn't understand Rule 450(b) or the SEC is being really, really difficult. In the end, you're going to have to serve somebody with a proper Brief. It doesn't matter who you are. You're still gonna have to get this right and properly serve a succinct and concise brief on somebody.

Might be a rock'n' roll addict prancing on the stage
Might have money and drugs at your commands, women in a cage
You may be a business man or some high degree thief
They may call you Doctor or they may call you Chief.
But you're gonna have to serve somebody, yes indeed
You're gonna have to serve somebody,
Well, it may be the devil or it may be the Lord
But you're gonna have to serve somebody.


Topics: Rule 450  SEC  Briefs  Bill Singer  BrokeAndBroker  
 

 
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