Initiated By
FINRA
Allegations
FINRA RULE 2010: OLSON'S MEMBER FIRM PROVIDED HER WITH A CORPORATE CREDIT CARD, INTENDED TO BE USED ONLY FOR BUSINESS-RELATED PURPOSES. OLSON PERIODICALLY USED THE CORPORATE CREDIT CARD FOR PERSONAL EXPENSES. WHEN SHE ACCOUNTED FOR THOSE CHARGES ON THE FIRM'S INTERNAL COMPUTER SYSTEM, HER USUAL PRACTICE WAS TO DESIGNATE THEM AS PERSONAL, AND SHE, NOT THE FIRM, PAID FOR THEM. IN APRIL 2010, OLSON CONVERTED FUNDS FOR HER OWN USE WHEN SHE PURCHASED TWO IPODS AS GIFTS FOR HER RELATIVES USING HER MEMBER FIRM'S CORPORATE CREDIT CARD. THE COST OF THE IPODS WAS $740.10. OLSON THEN ACCESSED THE FIRM'S COMPUTERIZED EXPENSE REPORTING SYSTEM TO ACCOUNT FOR HER CREDIT CARD CHARGES INCURRED AND RATHER THAN DESIGNATE THE IPOD PURCHASES AS A PERSONAL EXPENSE, SHE KNOWINGLY DESIGNATED THE EXPENDITURE AS A BUSINESS EXPENSE. SHE FALSELY DESCRIBED THE EXPENSE AS OFFICE EQUIPMENT FOR A BRANCH CONFERENCE ROOM, ENTERING THE WORDS "BRANCH EQUIP FOR NEW COF ROOM" IN THE "DESCRIPTION" COLUMN OF THE REPORT.
Resolution
Decision
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Start Date
5/9/2014
Sanctions
Monetary Penalty other than Fines
Amount
$3,378.56
Regulator Statement
HEARING PANEL DECISION RENDERED JANUARY 4, 2013 WHEREIN OLSON IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR CONVERSION OF FIRM FUNDS, IN VIOLATION OF FINRA RULE 2010. OLSON IS ORDERED TO PAY COSTS IN THE AMOUNT OF $1,909.71. THE PAYMENT OF COSTS SHALL BE DUE ON A DATE SET BY FINRA, BUT NOT SOONER THAN 30 DAYS AFTER THIS DECISION BECOMES FINRA'S FINAL DISCIPLINARY ACTION IN THIS PROCEEDING. ON JANUARY 15, 2013, OLSON APPEALED THE DECISION TO THE NATIONAL ADJUDICATORY COUNCIL (NAC).
NAC DECISION RENDERED MAY 9, 2014. THE NATIONAL ADJUDICATORY COUNCIL (NAC) AFFIRMED THE FINDINGS AND SANCTION IMPOSED FOLLOWING APPEAL OF AN OFFICE OF HEARING OFFICERS (OHO) DECISION. THE SANCTION WAS BASED ON FINDINGS THAT OLSON SUBMITTED A FALSE EXPENSE REPORT AND CONVERTED HER MEMBER FIRM'S FUNDS BY OBTAINING PAYMENT FOR PERSONAL EXPENSES FOR WHICH CORPORATE REIMBURSEMENT WAS NOT ALLOWED. THE FINDINGS STATED THAT OLSON'S FIRM ISSUED HER A CORPORATE CREDIT CARD AND AS, THE FIRM PERMITTED, OLSON PERIODICALLY USED HER CORPORATE CREDIT CARD FOR BOTH BUSINESS AND PERSONAL REASONS. AN EXPENDITURE THAT WAS NOT REIMBURSABLE AS A CORPORATE EXPENSE UNDER THE FIRM'S EXPENSE ALLOWANCE POLICIES, HOWEVER, REMAINED OLSON'S PERSONAL RESPONSIBILITY. OLSON CHARGED $740.10 WORTH OF ELECTRONICS THAT WERE PERSONAL EXPENSES TO HER CORPORATE CREDIT CARD. OLSON ACCOUNTED FOR THE CHARGE USING THE FIRM'S EXPENSE MANAGEMENT SYSTEM BUT SHE DID NOT DESIGNATE THE PURCHASE AS A PERSONAL EXPENSE. INSTEAD, OLSON FALSELY CLAIMED THAT SHE INCURRED THE EXPENSE TO PURCHASE BRANCH OFFICE EQUIPMENT TO JUSTIFY THE OUTLAY AS A BUSINESS COST. OLSON'S FIRM PAID THE $740.10 THAT SHE INCURRED. THE FIRM BEGAN AN INVESTIGATION TO ADDRESS DISCREPANCIES IN OLSON'S USE OF HER CORPORATE CREDIT CARD AND AFTER THE FIRM'S AUDITOR ASKED OLSON WHICH CONFERENCE ROOM THE PURCHASE SUPPORTED, OLSON VOLUNTEERED THAT SHE HAD IN FACT PURCHASED THE ELECTRONICS AND ADMITTED THAT SHE FALSELY SUBMITTED THE EXPENDITURE FOR APPROVAL AS A BUSINESS EXPENSE. OLSON PROVIDED THE FIRM A VOLUNTARY, HAND-WRITTEN STATEMENT ACKNOWLEDGING HER MISCONDUCT AND THE FIRM IMMEDIATELY TERMINATED HER EMPLOYMENT. OLSON REIMBURSED THE FIRM THE $740.10 THAT THE FIRM PAID TO HER CORPORATE CREDIT CARD AS A RESULT OF HER FALSE ENTRY ON THE FIRM'S EXPENSE-MANAGEMENT SYSTEM.
On June 6, 2014, Olson submitted an application for review by the U.S. Securities and Exchange Commission (SEC) of the sanctions imposed on her by the FINRA Board of Governors.
SEC Decision rendered September 3, 2015 wherein the SEC sustained FINRA's imposition of sanctions and held the findings against Olson that she falsified an expense report and converted funds of her member firm.
The decision became final November 2, 2015.
