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WILLFULLY VIOLATED ARTICLE V, SECTION 2(C) OF FINRA'S BY-LAWS, FINRA RULES 1122, 2010, INTERPRETATIVE MATERIAL 1000-1, VIOLATED FINRA RULE 2010, NASD RULE 2110, - TAMMYE LARSEN ACCEPTED GIFTS AND CASH TOTALING MORE THAN $10,000 FROM HER MEMBER FIRM'S CUSTOMER, AND WAS APPOINTED AS A SUCCESSOR TRUSTEE TO THE CUSTOMER'S LIVING TRUST. LARSEN FALSELY REPRESENTED ON ANNUAL FIRM QUESTIONNAIRES THAT SHE HAD NOT RECEIVED GIFTS FROM FIRM CUSTOMERS IN EXCESS OF $100 AND DID NOT DISCLOSE WHETHER SHE HAD SERVED AS FIDUCIARY FOR A FIRM CUSTOMER ALTHOUGH THE FIRM'S PROCEDURES PROHIBITED REGISTERED REPRESENTATIVES FROM ACCEPTING GIFTS AT OR UNDER $100 UNLESS RECEIVING PRIOR FIRM APPROVAL AND THE FIRM'S PROCEDURES REQUIRED FIDUCIARY APPOINTMENTS COULD NOT BE ACCEPTED WITHOUT THE FIRM'S PRIOR WRITTEN APPROVAL. LARSEN ALSO RECEIVED GIFTS, INCLUDING JEWELRY, CARS AND OUT OF TOWN TRIPS FROM THE CUSTOMER IN EXCESS OF $100. LARSEN WAS APPOINTED POWER OF ATTORNEY (POA)WITH RESPECT TO THE CUSTOMER'S FINANCIAL ASSETS BUT THE POA DID NOT GIVE HER AUTHORITY TO USE THE CUSTOMER'S ASSETS FOR HER OWN BENEFIT. AFTER THE CUSTOMER HAD MOVED TO AN ASSISTED LIVING FACILITY, LARSEN WROTE A LARGE NUMBER OF CHECKS TO HERSELF AND DEPOSITED THEM INTO HER PERSONAL ACCOUNTS AND USED THE CHECKS NOT ONLY FOR THE CUSTOMER'S BENEFIT BUT FOR OWN BENEFIT AS WELL, COMMINGLING THE CUSTOMER'S FUNDS WITH HER OWN. LARSEN DISCLOSED HER FIDUCIARY RELATIONSHIP ON A MORE RECENT FIRM COMPLIANCE QUESTIONNAIRE AND THE FIRM REQUIRED HER TO SUBMIT A WRITTEN REQUEST TO ACT AS A FIDUCIARY WHICH THE FIRM THEN DENIED AND TERMINATED HER EMPLOYMENT. LARSEN FILED A PETITION FOR BANKRUPTCY BUT FAILED TO AMEND HER FORM U4 TO REFLECT THE FILING.
Resolution
Acceptance, Waiver & Consent(AWC)
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Duration
Indefinite
Start Date
11/8/2012
Regulator Statement
WITHOUT ADMITTING OR DENYING THE FINDINGS, LARSEN CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, SHE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. THIS SETTLEMENT INCLUDES A FINDING THAT LARSEN WILLFULLY OMITTED TO STATE A MATERIAL FACT ON A FORM U4, AND THAT UNDER SECTION 3(A)(39)(F) OF THE SECURITIES ACT OF 1934 AND ARTICLE III, SECTION 4 OF FINRA'S BY-LAWS, THIS OMISSION /MISREPRESENTATION MAKES HER SUBJECT TO A STATUTORY DISQUALIFICATION WITH RESPECT TO ASSOCIATION WITH A MEMBER.
2/17/2012
Regulatory
Final
Initiated By
KANSAS SECURITIES COMMISSIONER
Allegations
LARSEN FAILED TO DISCLOSE TO HER FIRM OR ON FORM U-4, A BANKRUPTCY DATED 11-25-2009. LARSEN ALSO ACCEPTED SUBSTANTIAL GIFTS, INCLUDING CASH AND A VEHICLE, FROM A CLIENT DURING HER TIME AS A REGISTERED REPRESENTATIVE OF MSSB, A VIOLATION OF NASD RULE 3060.
Resolution
Stipulation and Consent
Bar
Bar (Permanent)
Registration Capacities Affected
ALL CAPACITIES.
Duration Explanation
FOREVER
License(s)
The broker is not currently registered with any state or SRO.
A brokerage firm, also called a broker-dealer, is in the business of buying and selling securities – stocks, bonds, mutual funds, and certain other investment products – on behalf of its customer (as broker), for its own bank (dealer), or both. Individuals who work for broker-dealers - the sales personnel are commonly referred to as brokers.
IA
Investment Adviser
An investment adviser is paid for providing advice about securities to clients. In addition, some investment advisers manage investment portfolios and offer financial planning services.
Disclosures
Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.
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Disclosures can be customer complaints or arbitrations, regulatory actions, employment terminations, bankruptcy filings and certain civil or criminal proceedings that they were a part of.