Initiated By
FINRA
Allegations
FINRA RULE 2010, NASD RULES 2110, 3110: MENDEZ HAD AN ORAL UNDERSTANDING AND PRACTICE WITH HER MEMBER FIRM WHEREBY THE FIRM AND MENDEZ SHARED EQUALLY (I.E., 50/50) IN CERTAIN ADVERTISING AND MARKETING COSTS, SUBJECT TO THE FIRM'S APPROVAL. PURSUANT TO THE ORAL UNDERSTANDING AND PRACTICE, MENDEZ WAS TO PLACE ADVERTISING IN LOCAL RADIO AND PRINT MEDIA AND ENGAGE IN MARKETING ACTIVITIES, SUBJECT TO APPROVAL BY THE FIRM. DURING A PERIOD, MENDEZ SOUGHT REIMBURSEMENT FOR FICTITIOUS EXPENSES IN THE APPROXIMATE AMOUNT OF $8,218.86, OF WHICH THE FIRM PAID APPROXIMATELY $6,022.50. TO OBTAIN THE EXCESS REIMBURSEMENTS, MENDEZ SUBMITTED INACCURATE REQUESTS FOR REIMBURSEMENT AND FALSE SUPPORTING DOCUMENTS THAT SHE CREATED OR ALTERED. AS A RESULT OF SUBMITTING FALSIFIED REQUESTS FOR REIMBURSEMENT AND SUPPORTING DOCUMENTATION ON EXPENSE REPORTS, AND ACCEPTING PAYMENT FROM THE FIRM, MENDEZ WRONGLY MISAPPROPRIATED APPROXIMATELY $6,022.50 FROM THE FIRM FOR MENDEZ'S OWN USES AND BENEFIT. IN CONNECTION WITH THE MISAPPROPRIATION, MENDEZ SUBMITTED EXPENSE REPORTS WITH SUPPORTING DOCUMENTATION THAT CONTAINED ENTRIES THAT PURPORTED TO REFLECT LEGITIMATE AND ELIGIBLE BUSINESS EXPENSES WHEN THEY WERE, IN FACT, INACCURATE AND OTHERWISE FABRICATED EXPENSES, AND FALSIFIED BANK AND CREDIT CARD PAYMENT RECORDS. BY CREATING AND SUBMITTING FOR REIMBURSEMENT FALSE EXPENSE REPORTS AND SUPPORTING DOCUMENTS, MENDEZ CREATED INACCURATE BOOKS AND RECORDS, WHICH THE FIRM MAINTAINED, IN CONTRAVENTION OF EXCHANGE ACT RULE 17A-3.
Resolution
Acceptance, Waiver & Consent(AWC)
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Start Date
1/10/2014
Regulator Statement
WITHOUT ADMITTING OR DENYING THE FINDINGS, MENDEZ CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, SHE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.