FINRA

Without admitting or denying the findings, Stallings consented to the sanction and to the entry of findings that she circumvented her member firm's supervisory system and procedures and prevented the firm from properly supervising her by failing to disclose that she was named as power of attorney for a firm customer, had custody of two firm customers' bank accounts, and was named as successor trustee and beneficiary of a firm customer's trust. The findings stated that the two firm customers, for whom Stallings had custody of their bank accounts, designated her as their transfer-on-death beneficiary to their accounts, thereby upon the customers' deaths more than $60,000 passed to Stallings from the customers' bank accounts. In addition, one of the two customers appointed Stallings as successor trustee over the customer's living trust and named Stallings as a beneficiary of the trust granting her a $248,000 payment from the trust. Moreover, the firm's supervisory procedures strictly prohibited registered representatives from taking custody of money, or other property belonging to others. Additionally, its procedures provided that registered representatives should not be listed on a (non-family) transfer-on-death account. If the client is still alive, the advisor should remove himself or herself as beneficiary immediately. Further, the firm's supervisory procedures required that its registered representatives request and obtain approval prior to acting as a power of attorney for a firm customer. The findings also stated that Stallings improperly used approximately $5,300 of a firm customer's funds to pay for her personal expenses rather than return the funds (dividends and interest) to the beneficiaries of the brokerage account. The findings also included that Stallings made false statements and misrepresentations to her firm on annual compliance questionnaires, falsely stating she had not been granted control over any customer assets and falsely denying she had been granted any power of attorney over a firm customer. On the firm's request form for an individual to act as trustee for a customer, Stallings falsely stated that the customer was her aunt.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All capacities

Indefinite

11/19/2018

LPL Financial LLC

Discharged

Violation of Firm policy regarding fiduciary capacities and being a joint owner on two different clients banking accounts.