FINRA

Without admitting or denying the findings, Lay consented to the sanctions and to the entry of findings that he engaged in unauthorized trading by effecting transactions in customers' accounts without first obtaining authorization from each customer. The findings stated that in three separate customers' accounts, Lay purchased and sold securities totaling approximately $184,000, without receiving express authorization from the customers prior to execution, earning $180 in commissions. Instead, despite the absence of signed, written trading authorization forms, Lay relied on authorization he received from each customer's respective spouse to execute the trades. Likewise, without prior express authorization, Lay effected two additional securities transactions in another customer's account totaling approximately $104,000, earning $87 in commissions. Lay also entered and subsequently deleted inaccurate notes into his member firm's client relationship management system in connection with these two transactions, indicating that he spoke with the customer prior to entering the trades in her account when he did not actually speak with her until several days after execution.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$7,500.00

Disgorgement

$267.00

Suspension

all capacities

two months

1/3/2022

3/2/2022

plus interest

RAYMOND JAMES & ASSOCIATES, INC

Discharged

Unauthorized trading activity by accepting emailed trading instructions without verbal confirmation and accepting trading instructions from persons without approved trading authority on client accounts.