CFP Board Censures Improper CFP® Certificant Conduct

Certified Financial Planner Board of Standards Inc. today announced public disciplinary actions against the following individuals' rights to use the CFP® certification marks, effective immediately.

STATE	NAME	LOCATION	DISCIPLINE
California	Ralph G. Adamo	Newport Beach	Letter of Admonition
	Gwendolyn Biggs	Sacramento	Letter of Admonition
	Steven E. Fairchild	Gold River	Letter of Admonition
	Terry L. Jones	Costa Mesa	Letter of Admonition
	W. Aubrey Morrow	San Diego	Letter of Admonition
	Mark D. Romano	Lakewood	Revocation
Connecticut	David J. Scranton	Westbrook	Suspension
Kansas	John M. Kittle	Wichita	Revocation
Maryland	Thomas S. Greeves	Rockville	Revocation
Massachusetts	Anthony J. Bille	Hopkinton	Revocation
Michigan	James Currier	Bloomfield Hills	Revocation
New Jersey	Robert J. Calamunci	Tinton Falls	Letter of Admonition
	Robert W. Crowther	New Jersey Ocean	Letter of Admonition
North Carolina	Marshall E. Melton	Greensboro	Revocation
Pennsylvania	Howard S. Coff	Holland	Revocation
	William T. Neely	Grove City	Letter of Admonition
	David L. Rothman	Trevose	Letter of Admonition
	Theodore G. Rothman	Trevose	Letter of Admonition
Tennessee	Catherine M. Nolen	Nashville	Suspension
Texas	Marianne Springer Miller	San Antonio	Suspension
	Travis D. Wakeley	Hurst	Revocation
Utah	Kevin D. Kunz	Bountiful	Revocation
Wisconsin	Edward A. Davig	Holmen	Letter of Admonition

Public disciplinary actions taken by CFP Board, in order of decreasing severity, include permanent revocation, suspension and letters of admonition. Under terms of the revocation, Anthony J. Bille, Howard S. Coff, James Currier, Thomas S. Greeves, John M. Kittle, Kevin D. Kunz, Marshall E. Melton, Mark D. Romano and Travis D. Wakeley no longer have the right to use the CFP marks. David J. Scranton's right to use the CFP® marks was suspended for six months, Marianne Springer Miller's right to use the CFP® marks was suspended for one year and one day, and Catherine M. Nolen's right to use the CFP® marks was suspended for three years. CFP Board issued Ralph G. Adamo, Gwendolyn Biggs, Robert J. Calamunci, Robert W. Crowther, Edward A. Davig, Steven E. Fairchild, Terry L. Jones, W. Aubrey Morrow, William T. Neely, David L. Rothman and Theodore G. Rothman letters of admonition; all retain the right to use the CFP marks.

These disciplinary actions were taken by the Board of Professional Review, a board of CFP® certificants that interprets and applies CFP Board's Code of Ethics and Professional Responsibility and Financial Planning Practice Standards as well as investigates, deliberates and takes appropriate action with respect to alleged violations of the Code of Ethics or Practice Standards by CFP® certificants. The basis for each decision can be found in the attached report. Consumers can check on a planner's disciplinary history and certification status with CFP Board on the Web site.

DISCIPLINARY ACTION REPORT
February 2005

Public Letters of Admonition

CALIFORNIA

Ralph G. Adamo (Newport Beach): In November 2004, CFP Board countered Mr. Adamo's offer of settlement wherein he admitted to violating CFP Board's Code of Ethics and Professional Responsibility and consented to a private censure. Mr. Adamo consented to findings that he borrowed funds from clients, commingled monies, and reimbursed investor losses without prior broker/dealer consent. Pursuant to the settlement, Mr. Adamo consented to a letter of admonition.

Gwendolyn Biggs (Sacramento): In December 2004, CFP Board issued Ms. Biggs a public letter of admonition for matters related to a complaint brought against her by a former client. After conducting an investigation and holding a hearing on the matters, the Board of Professional Review (Board) found that: 1) Ms. Biggs recommended that her client cash out annuities he inherited from his spouse without understanding the tax implications associated therewith; 2) she recommended and sold the same client more annuities, which were unsuitable given his age, other assets and income; 3) without first consulting her broker/dealer, she took advantage of her client's trust and convinced him to loan her $300,000 for the purchase of a condominium in Hawaii; 4) without first conducting a thorough analysis regarding the interests and objectives of her client, she recommended he surrender the annuities he had inherited and purchase new annuities - this recommendation did not benefit Ms. Biggs' client, but did produce substantial commissions for her; 5) she attempted to obtain and/or did obtain a loan from her client wherein she was only obligated to make payments under the proposed loan until his death and there was no obligation for her to repay the loan in full or compensate the client's estate upon his death; 6) the loan she attempted to take and/or took from her client was not in his best interests; and 7) she failed to disclose to her client, in writing, the risks relating to his loaning substantial amounts of money to her. Ms. Biggs retains the right to use the CFP marks.

Steven E. Fairchild (Gold River): In December 2004, CFP Board issued Mr. Fairchild a public letter of admonition after its investigation of a civil lawsuit alleging negligence, breach of fiduciary duty, and intentional misrepresentation arising out of his provision of estate planning services, which included the preparation of a Trust and an amendment to the Trust. The amendment to the Trust was rendered invalid, and as a result, the plaintiffs alleged they did not obtain the distributions to which they were entitled. The matter was settled, and Mr. Fairchild personally contributed toward the settlement amount. The Board of Professional Review (Board) found that Mr. Fairchild prominently displayed his name and allowed his company's name to be used in conjunction with legal estate documents which were deemed invalid by the court. In mitigation, the Board considered that Mr. Fairchild has changed his practice process so that he no longer bills for legal services, encloses his name on documents, and directly contracts with estate attorneys. In aggravation, the Board considered that Mr. Fairchild continues to provide outside estate attorney fact finders to clients and that Mr. Fairchild's assistant notarized the Amendment that Mr. Fairchild testified he had no knowledge of. Mr. Fairchild retains the right to use the CFP marks.

Terry L. Jones (Costa Mesa): In December 2004, CFP Board issued Mr. Jones a public letter of admonition after its investigation of a grievance submitted by his former client, generally alleging that Mr. Jones implemented unsuitable investments, failed to adequately disclose his compensation structure, and made misrepresentations regarding the costs of the investments he recommended. The grievant also incorporated her complaint in a National Association of Securities Dealers (NASD) arbitration proceeding that Mr. Jones' broker/dealer settled for $40,000. After a hearing was conducted, the Board of Professional Review (Board) found that Mr. Jones moved the grievant's investments from conservative positions to aggressive, high-risk positions that were unsuitable, and misrepresented to CFP Board that he had never had a prior complaint. In aggravation, the Board considered that Mr. Jones' broker/dealer paid a $40,000 settlement to conclude the NASD arbitration and that CFP Board previously issued Mr. Jones a cautionary letter as a result of a client grievance that related to issues similar to those in the current case. Mr. Jones retains the right to use the CFP marks.

W. Aubrey Morrow (San Diego): In January 2005, CFP Board issued Mr. Morrow a letter of admonition after it received a grievance from another CFP certificant who previously worked with Mr. Morrow. After investigating the certificant's allegations and conducting a hearing, the Board of Professional Review (Board) found that: 1) previous versions of Mr. Morrow's Financial Planning Association (FPA) Web site profile contained misleading statements with regard to his receipt of referral fees from other professionals; 2) previous versions of Mr. Morrow's FPA Web site profile contained misleading statements with regard to his firm's registration with the Securities and Exchange Commission; 3) Mr. Morrow's firm's Retainer Agreement historically contained misleading statements to clients, wherein the Retainer Agreement stated that all disputes must be first submitted to mediation according to standards established by the "Certified Financial Planner Board of Standards" when no such mediation process exists; and 4) despite representations in his firm's Retainer Agreement that investment of assets would be done on a "fee-only" basis, Mr. Morrow and other associates of his firm received commissions and other compensation, including referral fees, from products Mr. Morrow and/or his associates recommended and sold to clients. Accordingly, the Board determined to issue Mr. Morrow a public letter of admonition with respect to its findings. Mr. Morrow appealed the findings; however, after a review of the record, Mr. Morrow's petition for appeal and CFP Board's response thereto, the Board of Appeals determined to affirm CFP Board's findings and the discipline imposed. Mr. Morrow retains the right to use the CFP marks.

NEW JERSEY

Robert J. Calamunci (Tinton Falls): In December 2004, CFP Board issued Mr. Calamunci a public letter of admonition after its investigation of a National Association of Securities Dealers (NASD) inquiry Mr. Calamunci disclosed to CFP Board. After a hearing was conducted, the Board of Professional Review (Board) found that Mr. Calamunci entered into a Letter of Acceptance, Waiver and Consent with the NASD whereby he consented to the entry of findings that he recommended numerous Class B mutual fund transactions to two customers even though the transactions were unsuitable for those customers, in violation of NASD rules, and consented to accept a ten-day suspension from association with any NASD member in any capacity and to pay a $13,460.15 fine. In aggravation, the Board considered that Mr. Calamunci did not know his broker/dealer's disclosure requirements, that the amount invested in B shares was large, that the client to whom Mr. Calamunci sold the B shares was vulnerable, being a terrorist attack victim and friend of Mr. Calamunci, and the lack of recognition of B share issues at the time of the incident. Mr. Calamunci retains the right to use the CFP marks.

Robert W. Crowther (Ocean): In January 2005, CFP Board issued Mr. Crowther a public letter of admonition after its investigation of his entry into a Letter of Acceptance Waiver and Consent (AWC) with the National Association of Securities Dealers (NASD). After a hearing, the Board of Professional Review (Board) found that Mr. Crowther entered into an AWC with the NASD wherein he consented to the entry of findings that he failed to properly supervise a subordinate who effected unsuitable transactions and made unsuitable investment recommendations to an elderly client; consented to the entry of findings that he failed to properly supervise that subordinate for a period of one year with respect to the subordinate's unsuitable recommendations and transactions for that elderly client; and agreed to a thirty business-day suspension and to pay a $5,000 fine. The Board further found that as a CFP certificant who supervises, Mr. Crowther needs to set the best example possible for his subordinates.

PENNSYLVANIA

William T. Neely (Grove City): In December 2004, CFP Board issued Mr. Neely a public letter of admonition related to conduct regarding a customer complaint a former client filed against him, which resulted in a regulatory investigation. After conducting its own investigation and holding a hearing on the matters, the Board of Professional Review (Board) found that: 1) Mr. Neely failed to execute a stop loss order from his client resulting in significant losses in the client's accounts; and 2) the National Association of Securities Dealers (NASD) deemed that Mr. Neely violated one of its conduct rules when he failed to act upon the instructions from his client to enter a stop loss order that would be executed if the aggregate value of the client's accounts fell below $2 million. In aggravation, the Board considered that Mr. Neely failed to fully cooperate with CFP Board's investigation.

David L. Rothman (Trevose): In December 2004, CFP Board issued Mr. Rothman a public letter of admonition after its investigation of an arbitration, a mediation, his false attestations on applicable renewal forms with respect to those proceedings, and a Letter of Acceptance, Waiver & Consent (AWC) Mr. Rothman entered into with the National Association of Securities Dealers (NASD) in which he was fined $5,000 and suspended for ten business days in connection with the sale of Class S shares of mutual funds. Mr. Rothman failed to notify CFP Board of his professional suspension within ten calendar days as required. After a hearing was conducted, the Board of Professional Review (Board) found that Mr. Rothman entered into an AWC with the NASD whereby he consented to findings that he recommended and effected purchases of Class S shares of mutual funds in customers' accounts without having reasonable grounds to believe that such recommendations were suitable because, in all instances, one or more of the other fund share classes were less costly and/or otherwise more advantageous to investors, and pursuant to which he was fined $5,000 and suspended from association for ten days. The Board also found that Mr. Rothman falsely attested on his Renewal Form with regard to his involvement in the mediation and arbitration, and that he failed to notify CFP Board of his professional suspension within ten calendar days as required. Mr. Rothman retains the right to use the CFP marks.

Theodore G. Rothman (Trevose): In December 2004, CFP Board issued Mr. Rothman a public letter of admonition after its investigation of an arbitration, a mediation, his false attestations on applicable renewal forms with respect to those proceedings, and a Letter of Acceptance, Waiver & Consent (AWC) Mr. Rothman entered into with the National Association of Securities Dealers (NASD) in which he was fined $45,000 and suspended for thirty days in connection with the sale of Class S shares of mutual funds. Mr. Rothman failed to notify CFP Board of his professional suspension within ten calendar days as required. After a hearing was conducted, the Board of Professional Review (Board) found that Mr. Rothman entered into an AWC with the NASD whereby he consented to findings that he recommended and effected purchases of Class S shares of mutual funds in customers' accounts without having reasonable grounds to believe that such recommendations were suitable because, in all instances, one or more of the other fund share classes were less costly and/or otherwise more advantageous to investors, and pursuant to which he was fined $45,000 and suspended from association for thirty days. The Board also found that Mr. Rothman falsely attested on his Renewal Form with regards to his involvement in the mediation and arbitration, and that he failed to notify CFP Board of his professional suspension within ten calendar days as required. Mr. Rothman retains the right to use the CFP marks.

WISCONSIN

Edward A. Davig (Holmen): In December 2004, CFP Board issued Mr. Davig a public letter of admonition. After an investigation and hearing, CFP Board made several findings, including findings that Mr. Davig over-concentrated a 73-year-old client's investments in growth stocks, given the client's age and risk tolerance.

Suspension

CONNECTICUT

David J. Scranton (Westbrook): In December 2004, CFP Board suspended Mr. Scranton's right to use the CFP marks for a period of six months for matters related to a customer complaint and a National Association of Securities Dealers consent agreement. After conducting an investigation and holding a hearing, the Board of Professional Review found that: 1) Mr. Scranton submitted an insurance policy premium payment to an insurance company on behalf of his clients, as if it was coming directly from the clients, even though the insurance company explained to him that payments must come directly from policy holders; 2) Mr. Scranton paid a premium payment towards his client's life insurance policy even though the clients had expressed their intent to cancel the policy; 3) Mr. Scranton's former broker/dealer terminated his registration therewith after it became aware that, in violation of the insurance company's policy, he paid a premium payment for a life insurance policy on behalf of his clients; 4) Mr. Scranton entered into a Letter of Acceptance, Waiver and Consent with the NASD wherein he agreed to a finding that he paid one premium of his clients' variable life insurance policy without their consent; 5) Mr. Scranton agreed to pay a fine to the NASD of up to $5,000 and to serve a ten-day suspension between January 2, 2004 and January 12, 2004; and 6) Mr. Scranton failed to notify CFP Board of his professional suspension within ten calendar days as required.

TENNESSEE

Catherine M. Nolen (Nashville): In December 2004, CFP Board suspended Ms. Nolen's right to use the CFP marks for a period of three years after its investigation of a grievance filed with CFP Board generally alleging that Ms. Nolen mismanaged the estate of the grievant's aunt, for whom Ms. Nolen was executrix, trustee, and financial advisor. After a hearing was conducted, the Board of Professional Review (Board) found that: 1) Ms. Nolen took loans for her personal benefit from her client, an Estate and Trust, that were high-risk investments not in the interest of the Estate and Trust's beneficiaries, given that the Estate and Trust were to provide income to the beneficiaries; 2) Ms. Nolen implemented unsuitable investments by placing most of the estate's assets in aggressive growth stocks and demand notes; 3) Ms. Nolen took client loans that were inappropriate and involved gross conflict of interests, given Ms. Nolen's roles as executrix and trustee for the Estate and Trust and her roles as owner and personal guarantor of the company that took the loans; 4) Ms. Nolen failed to adequately disclose those conflicts of interest to the beneficiaries; and 5) Ms. Nolen failed to ensure that the loans from the Estate and Trust to her business were repaid. In mitigation, the Board considered that Ms. Nolen was remorseful and stated that she would accept any fair treatment. In aggravation, the Board considered that Ms. Nolen owed back taxes which she stated were in an "uncollectible" status and that she might declare bankruptcy if the IRS attempted to make her pay the back taxes. The Board also considered in aggravation Ms. Nolen's statements that she was unsure why the Board had the right to question her actions.

TEXAS

Marianne Springer Miller (San Antonio): In January 2005, CFP Board suspended Ms. Miller's right to use the CFP marks for a period of one year and one day. Ms. Miller disclosed to CFP Board that she was named, along with her current and former broker/dealers, in an arbitration claim wherein her client claimed damages in excess of $500,000 and generally alleged improper handling of her securities account over a six-year period. After an investigation was conducted and a hearing held, the Board of Professional Review (Board) found that: 1) Ms. Miller assisted her client in completing paperwork for the purchase of an individual stock and when helping the client respond to the questions therein regarding the client's sophistication, Ms. Miller told the client the question was merely asking whether she had previously owned stock and/or mutual funds; 2) even though Ms. Miller may have disclosed her status as a board member of the company she was helping her client to purchase stock in, she did not explain to her client the potential conflict of interest she had in acting as both her financial advisor and a board member of the company the client was purchasing the stock from; 3) Ms. Miller told her client that the stock was a great investment and used her own experiences with purchasing the stock to encourage her client to invest; however, she failed to mention to her client that the stock was a speculative investment which contained a high degree of risk; 4) even if Ms. Miller was not managing her client's portfolio, she failed to explain to her client the scope of her representation and the client relied on her marketing of the stock as a basis for her decisions to continue buying more shares of the stock; 5) Ms. Miller acted as the designated representative for her client's purchase of the stock while serving as a board member of the company from which the stock was purchased; 6) Ms. Miller failed to exercise diligence when managing her client's portfolio and allowed her client's portfolio to become over-concentrated with holdings in one company's stock; 7) when the company with which her client held the stock needed additional financing, Ms. Miller assisted her client in pledging securities from her portfolio for additional stock, which resulted in the client's portfolio being over-concentrated in a single stock; and 8) Ms. Miller knew or should have known that a large portion of her client's portfolio was being/had been pledged as security for stock in the company for which she was a board member and failed to discourage her client from such pledges. Ms. Miller filed a petition for appeal of the Board's findings and the discipline imposed; however, after reconsideration Ms. Miller requested that the Board of Appeals approve her request for withdrawal of the petition and impose the discipline initially imposed. The Board of Appeals accepted this request.

Revocation

CALIFORNIA

Mark D. Romano (Lakewood): In January 2005, CFP Board permanently revoked Mr. Romano's right to use the CFP certification marks following its discovery that he entered into a Letter of Acceptance, Waiver and Consent (AWC) with the National Association of Securities Dealers (NASD) in which he consented to findings that he engaged in outside business activities without giving prompt written notice to his member firms and consented to an eighteen-month suspension from association with any member firm in any capacity and to pay a fine of $27,315 prior to re-association with any member firm. After a hearing, the Board of Professional Review found that Mr. Romano: 1) entered into an AWC with the NASD pursuant to which he consented to findings that he engaged in outside business activities without giving proper written notice to his member firms, and consented to an 18-month suspension from association with any member firm in any capacity and a fine of $27,315; 2) falsely attested on his Renewal Form with regard to an NASD arbitration filed against him; and 3) failed to notify CFP Board of his professional suspension within ten calendar days as required. In mitigation, the Board considered that Mr. Romano was going through a period of extreme stress in his personal life. In aggravation, the Board considered that Mr. Romano made inappropriate investment recommendations to his client and failed to inform his broker/dealer of outside business and investment recommendations.

KANSAS

John M. Kittle (Wichita): In January 2005, CFP Board permanently revoked Mr. Kittle's right to use the CFP marks after he failed to respond to CFP Board's Complaint investigating a Letter of Acceptance, Waiver and Consent (AWC) he entered into with the National Association of Securities Dealers (NASD), pursuant to which he was fined $5,000 and suspended from association with any NASD member in any capacity for ten business days. Without admitting or denying the allegations, Mr. Kittle consented to the aforementioned sanctions and to the entry of findings that he recommended unsuitable mutual funds to public customers. The findings also stated that based on Mr. Kittle's recommendations, the customer purchased the mutual funds, and that instead of Class B shares, Mr. Kittle should have recommended that the customers purchase Class A to eliminate higher annual expenses. Mr. Kittle failed to notify CFP Board of his professional suspension within ten calendar days as required, and he failed to respond to CFP Board requests for information as required. Because Mr. Kittle failed to respond to CFP Board's Complaint, the allegations in the complaint were deemed admitted and an order of revocation was issued.

MARYLAND

Thomas S. Greeves (Rockville): In November 2004, CFP Board permanently revoked Mr. Greeves' right to use the CFP marks after he failed to respond to CFP Board's Amended Complaint investigating two grievances filed against him with CFP Board. Mr. Greeves failed to respond to CFP Board requests for information as required. CFP Board subsequently discovered that in or around 2003, the Maryland Securities Commissioner (MSC) issued an Order to Show Cause against Mr. Greeves to which he failed to timely file an answer. Accordingly, the MSC issued a Final Order which concluded that Mr. Greeves and his firm: 1) engaged in dishonest and unethical practices, and in a fraudulent course of business which operated as a fraud on his investment advisory clients; 2) omitted to state, and misrepresented, material facts in connection with providing investment advice to clients; 3) failed to make an annual offer of their disclosure documents to their advisory clients; 4) failed to comply with the custody provisions promulgated under the Code of Maryland's regulations; 5) failed to file audited balance sheets as required by the Code of Maryland's regulations; 6) failed to keep the information contained in their application complete and accurate as required by the Code of Maryland's regulations; 7) made false and misleading statements in documents filed with the MSC; 8) failed to make, keep, and preserve certain books and records as required by the Code of Maryland's regulations; 9) filed an application for renewal registration which was misleading with respect to a material fact; 10) willfully violated or willfully failed to comply with the Maryland Securities Act; and 11) engaged in dishonest or unethical practice in the securities or investment advisory business. The MSC denied Mr. Greeves and his firm's application for renewal registration as an investment adviser in that state, permanently barred Mr. Greeves and his firm from engaging in the securities or investment advisory business in that state for or on behalf of any others, or from acting as principal or consultant in any entity so engaged, and assessed a civil monetary penalty in the amount of $48,919. Mr. Greeves failed to notify CFP Board of his professional bar within ten calendar days as required. Because Mr. Greeves failed to respond to CFP Board's Amended Complaint, the allegations in the Amended Complaint were deemed admitted and an order of revocation was issued.

MASSACHUSETTS

Anthony J. Bille (Hopkinton): In October 2004, CFP Board permanently revoked Mr. Bille's right to use the CFP marks after he failed to respond to CFP Board's Complaint investigating the recommendation by the Massachusetts Board of Bar Overseers (MBBO) for a four-year suspension of his license to practice law in connection with his professional services in which he acted as a trustee, lawyer and estate planner for a client without consultation with any other attorney. The MBBO also asserted that, after his client exhibited severe memory loss and possibly Alzheimer's disease, Mr. Bille took over responsibility for management of her checking accounts, and for several years, without the client's knowledge or consent, misappropriated and converted for his own use assets of a trust and other of the client's assets. Mr. Bille also executed two unsecured notes payable to one of the client's trusts, for which he made payments for approximately one year and then ceased making payments. The MBBO asserted that the liquid assets available from the client's trusts and personal accounts were insufficient to meet routine expenses. Following a hearing, the MBBO issued a report with, among others, the following findings: 1) Mr. Bille had no legal or actual authority to transfer or "loan" the client's assets to himself or use her assets for his own benefit; 2) when Mr. Bille transferred or "loaned" the client's assets to himself and used them for his own benefit without obtaining her consent, and without suggesting the client obtain independent counsel to advise her of the propriety of the proposed transfer, he engaged in a conflict of interest and entered into a business transaction with the client, in violation of state canon and disciplinary rules; and 3) when Mr. Bille transferred or "loaned" the client's assets to himself and used them for his own benefit, he intentionally misused his client's assets and temporarily deprived her of the use of those assets, in violation of state canon and disciplinary rules. The MBBO recommended Mr. Bille's license to practice law be suspended for four years. Mr. Bille failed to respond to repeated requests for information by CFP Board. Because Mr. Bille failed to respond to CFP Board's Complaint, the allegations in the complaint were deemed admitted and an order of revocation was issued.

MICHIGAN

James Currier (Bloomfield Hills): In October 2004, CFP Board permanently revoked Mr. Currier's right to use the CFP marks after he failed to respond to CFP Board's Complaint investigating a Letter of Acceptance, Waiver and Consent (AWC) he entered into with the National Association of Securities Dealers (NASD). Pursuant to the AWC, Mr. Currier, an associated person and the firm were fined $35,000 jointly and severally; the firm and Mr. Currier were also fined an additional $7,500, jointly and severally. Mr. Currier consented to the entry of finding that the firm, acting through a registered representative, failed to prepare and maintain an accurate and current ledger, current trial balance sheet, income statement and stock record, and failed to prepare and maintain adequate supporting documentation to evidence compliance with Securities and Exchange Commission (SEC) rules. The findings also stated that the firm, acting through the registered representative, failed to eviden