FINRA

FINRA RULE 2010, NASD RULES 2110, 3110: LAROSA RECEIVED ITEMIZED MONTHLY INVOICES FROM HIS COUNTRY CLUB, MANY OF WHICH LISTED PERSONAL EXPENSES THAT HE INCURRED, SUCH AS MEMBERSHIP DUES, FOOD, AND GOLF AND PRO SHOP FEES. NONE OF THESE PERSONAL EXPENSES WAS ALLOWED UNDER HIS MEMBER FIRM'S POLICIES. TO CAUSE HIS FIRM TO PAY THESE PERSONAL EXPENSES, LAROSA, OR OTHERS ACTING ON HIS BEHALF, HAD HIS COUNTRY CLUB GENERATE FALSE INVOICES TO DISGUISE THE PERSONAL EXPENSES AS LEGITIMATE BUSINESS EXPENSES. LAROSA, OR OTHERS ACTING ON HIS BEHALF, SUBMITTED 13 FALSE COUNTRY CLUB INVOICES THAT FALSELY REPRESENTED THAT LAROSA INCURRED ALLOWABLE BUSINESS EXPENSES, OR FALSELY REPRESENTED THE AMOUNT OF ALLOWABLE EXPENSES THAT HE INCURRED, AT THE COUNTRY CLUB. LAROSA, IN HIS ROLES AS BRANCH MANAGER AND COMPLEX MANAGER, APPROVED FOR PAYMENT FOUR OF THE FALSE INVOICES REFERRED TO ABOVE. THE FIRM BEGAN REQUIRING COVER SHEETS TO ACCOMPANY INVOICES SUBMITTED TO THE FIRM FOR PAYMENT. LAROSA, OR OTHERS ACTING ON HIS BEHALF, FURTHER MISREPRESENTED IN NOTES ON COVER SHEETS SUBMITTED WITH FOUR OF THE FALSE INVOICES THE PERSONAL UNAUTHORIZED EXPENSES AS ALLOWABLE BUSINESS EXPENSES OR THE AMOUNT OF ALLOWABLE EXPENSES THAT LAROSA INCURRED. BY SUBMITTING FALSE COUNTRY CLUB INVOICES AND FALSE COVER SHEETS, LAROSA, WITHOUT AUTHORIZATION, WILLFULLY CAUSED HIS FIRM TO PAY $23,337.24 TO THE COUNTRY CLUB FOR LAROSA'S PERSONAL EXPENSES. LAROSA AND HIS WIFE EACH HAD ACCESS TO AN ACCOUNT THAT THE FIRM MAINTAINED AT A GROCERY STORE CHAIN. THE FIRM MAINTAINED WRITTEN POLICIES STATING THAT EMPLOYEES COULD USE SUCH ACCOUNTS ONLY FOR APPROPRIATE BUSINESS PURPOSES. LAROSA AND HIS WIFE USED THE GROCERY STORE ACCOUNT WITHOUT AUTHORIZATION FOR TWO TYPES OF PURCHASES OF GOODS AND ITEMS FOR THEIR PERSONAL USE OR FOR THE USE OF OTHER FIRM EMPLOYEES. BY MISREPRESENTING THE NATURE OF THE PURCHASES, LAROSA CAUSED THE FIRM TO PAY THE GROCERY STORE FOR AT LEAST $63,000 IN IMPROPER EXPENSES. LAROSA, OR OTHERS ACTING ON HIS BEHALF, SUBMITTED 23 INVOICES FROM THE GROCERY STORE FOR THE EXPENSES DESCRIBED ABOVE TO THE FIRM FOR PAYMENT, AND IN SO DOING FALSELY REPRESENTED THAT ALL OF THE EXPENSES INCURRED WERE ALLOWABLE BUSINESS EXPENSES WHEN, IN FACT, AT LEAST $63,000 OF THE TOTAL WAS FOR PERSONAL OR OTHER UNAUTHORIZED, NON-REIMBURSABLE EXPENDITURES. LAROSA, OR OTHERS ACTING ON HIS BEHALF, FURTHER MISREPRESENTED THE UNAUTHORIZED TRANSACTIONS AS ALLOWABLE BUSINESS EXPENSES IN NOTES ON COVER SHEETS SUBMITTED WITH SEVEN OF THE INVOICES FOR PURCHASES AT THE GROCERY STORE. BY USING THE GROCERY STORE ACCOUNT FOR UNAUTHORIZED PERSONAL USE AND CAUSING THE FIRM TO PAY THE STORE, LAROSA CONVERTED AT LEAST $63,000 FROM HIS FIRM. LAROSA SUBMITTED, OR CAUSED OTHERS TO SUBMIT, FALSE INVOICES AND COVER SHEETS TO THE FIRM IN ORDER TO CAUSE THE FIRM TO PAY FOR UNAUTHORIZED PERSONAL EXPENSES. LAROSA ALSO SUBMITTED, OR CAUSED OTHERS TO SUBMIT, 16 ADDITIONAL FALSE INVOICES FROM THE COUNTRY CLUB AND TEN COVER SHEETS DESCRIBING THOSE EXPENSES IN ORDER TO CAUSE THE FIRM TO PAY THE COUNTRY CLUB FOR CERTAIN ALLOWED EXPENSES. BY SUBMITTING, OR CAUSING OTHERS TO SUBMIT, FALSE INVOICES AND COVER SHEETS TO HIS FIRM, LAROSA CAUSED THE FIRM TO VIOLATE SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-3 THEREUNDER.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

9/17/2013

WITHOUT ADMITTING OR DENYING THE FINDINGS, LAROSA CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.