FINRA

FINRA RULE 2010, NASD RULE 2110 - HARRY W. HUNT APPLIED FOR A $10,000 STUDENT LOAN ON BEHALF OF A RELATIVE AND AFFIXED THE ELECTRONIC SIGNATURE, ADDRESS AND SOCIAL SECURITY NUMBER OF A MEMBER FIRM CUSTOMER AS A CO-SIGNER ON THE LOAN, WITHOUT THE KNOWLEDGE OR CONSENT OF THE CUSTOMER, AND SUBMITTED THE LOAN APPLICATION FOR PROCESSING. IN FURTHERANCE OF THE LOAN APPLICATION, HUNT SUBMITTED A COPY OF HIS RELATIVE'S DRIVER'S LICENSE ON WHICH HE HAD ALTERED THE ADDRESS SO THAT IT MATCHED THE ADDRESS ON THE LOAN APPLICATION WHICH WAS HUNT'S BUSINESS ADDRESS. HUNT'S MEMBER FIRM REQUIRED THAT BUSINESS EXPENSES BE INCURRED AND PAID BY THE REPRESENTATIVE PRIOR TO REQUESTING REIMBURSEMENT. HUNT SUBMITTED NUMEROUS ELECTRONIC CLAIMS FOR REIMBURSEMENT TO HIS FIRM BY ALTERING PREVIOUSLY SUBMITTED REIMBURSEMENT FORMS, ALTERING THE FRONT OF A CHECK AND PHOTOCOPYING THE BACKS OF PREVIOUSLY CLEARED CHECKS IN SUPPORT OF THE CLAIMS, THEREBY CREATING THE APPEARANCE HIS CHECKS HAD CLEARED WHEN IN FACT HE HAD NOT YET WRITTEN THE CHECKS.

Decision

Bar (Permanent)

All Capacities

Indefinite

12/18/2012

Monetary Penalty other than Fines

$3,539.23

COMPLAINT FILED JUNE 28, 2010. HEARING PANEL DECISION RENDERED OCTOBER 17, 2011 WHEREIN HUNT IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY AND ORDERED TO PAY $2,027.15 IN COSTS. THE HEARING PANEL DISMISSED THE SECOND CAUSE OF THE COMPLAINT, FINDING THAT HUNT'S ALTERATION OF THE PHOTOCOPY OF HIS DAUGHTER'S LICENSE WAS NOT "BUSINESS RELATED." APPEALED TO THE NAC ON NOVEMBER 8, 2011. NAC DECISION RENDERED DECEMBER 18, 2012, WHEREBY THE FINDINGS ARE AFFIRMED AND THE SANCTIONS MODIFIED; THEREFORE, HUNT IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR VIOLATING FINRA RULE 2010 BY USING A CUSTOMER'S CONFIDENTIAL INFORMATION TO APPLY FOR A STUDENT LOAN WITHOUT THE CUSTOMER'S KNOWLEDGE OR CONSENT. HUNT WAS FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR SIX MONTHS FOR VIOLATING FINRA RULE 2010 AND NASD RULE 2110 BY FALSIFYING EXPENSE REPORTS. IN LIGHT OF THE BAR, THE NAC DID NOT IMPOSE THE FINE AND SUSPENSION. THE NAC ORDERED HUNT TO PAY $2,027.15 IN HEARING COSTS AND APPEAL COSTS OF $1,512.08. HUNT FILED AN APPLICATION FOR REVIEW TO THE SEC ON JANUARY 10, 2013. ON JANUARY 10, 2013, HUNT FILED A MOTION FOR A STAY OF THE BAR PENDING DETERMINATION OF HIS APPLICATION FOR REVIEW OF THE NAC DECISION. SEC ADMIN RELEASE 34-68755, JANUARY 29, 2013: ON JANUARY 29, 2013, THE SEC ORDERED THAT PENDING ITS REVIEW OF HIS APPEAL, HUNT'S MOTION TO STAY THE EFFECT OF FINRA'S DECISION IS DENIED; THEREFORE, HUNT'S BAR IN ANY CAPACITY IS EFFECTIVE DECEMBER 18, 2012. ON FEBRUARY 6, 2013, BY COPY OF A LETTER, HUNT WITHDREW HIS APPLICATION FOR REVIEW THAT WAS FILED TO THE SEC ON OR AROUND JANUARY 10, 2013. THEREFORE, HUNT'S BAR IN ALL CAPACITIES IS EFFECTIVE DECEMBER 18, 2012 FOR VIOLATING FINRA RULE 2010. HUNT WAS ALSO FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ALL CAPACITIES FOR SIX MONTHS FOR VIOLATING FINRA RULE 2010 AND NASD RULE 2110 BY FALSIFYING EXPENSE REPORTS. IN LIGHT OF THE BAR, THE NAC DID NOT IMPOSE THE FINE AND SUSPENSION. HOWEVER, THE NAC ORDERED HUNT TO PAY $2,027.15 IN HEARING COSTS AND APPEAL COSTS OF $1,512.08. THEREFORE, THE DECISION BECAME FINAL JANUARY 22, 2013.

COMPLAINT FILED JUNE 28, 2010. HEARING PANEL DECISION RENDERED OCTOBER 17, 2011 WHEREIN HUNT IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY AND ORDERED TO PAY $2,027.15 IN COSTS. THE HEARING PANEL DISMISSED THE SECOND CAUSE OF THE COMPLAINT, FINDING THAT HUNT'S ALTERATION OF THE PHOTOCOPY OF HIS DAUGHTER'S LICENSE WAS NOT "BUSINESS RELATED." APPEALED TO THE NAC ON NOVEMBER 8, 2011. NAC DECISION RENDERED DECEMBER 18, 2012, WHEREBY THE FINDINGS ARE AFFIRMED AND THE SANCTIONS MODIFIED; THEREFORE, HUNT IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR VIOLATING FINRA RULE 2010 BY USING A CUSTOMER'S CONFIDENTIAL INFORMATION TO APPLY FOR A STUDENT LOAN WITHOUT THE CUSTOMER'S KNOWLEDGE OR CONSENT. HUNT WAS FINED $10,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR SIX MONTHS FOR VIOLATING FINRA RULE 2010 AND NASD RULE 2110 BY FALSIFYING EXPENSE REPORTS. IN LIGHT OF THE BAR, THE NAC DID NOT IMPOSE THE FINE AND SUSPENSION. THE NAC ORDERED HUNT TO PAY $2,027.15 IN HEARING COSTS AND APPEAL COSTS OF $1,512.08. IF NO FURTHER ACTION, DECISION IS FINAL JANUARY 21, 2013.