Initiated By
FINRA
Allegations
FINRA RULE 2010 - STUART SIEGEL WAS APPOINTED PRESIDENT OF A FOUNDATION ESTABLISHED AFTER THE DEATH OF ONE OF HIS CUSTOMERS AND OPENED A BROKERAGE ACCOUNT AT HIS MEMBER FUND TO FUND ITS ACTIVITIES. SIEGEL OBTAINED HIS FIRM'S PERMISSION TO SERVE AS PRESIDENT BUT FIRM POLICIES PROHIBITED HIM FROM RECEIVING ANY COMPENSATION AND FROM SERVING AS THE REGISTERED REPRESENTATIVE FOR THE FOUNDATION'S BROKERAGE ACCOUNT. SIEGEL'S ROLE INCLUDED REVIEW OF GRANTS AND DONATIONS AND HE WAS RESPONSIBLE FOR PLACING TRADES. SIEGEL HAD ACCESS TO THE FOUNDATION'S CHECKING ACCOUNT, COULD WITHDRAW FUNDS, AND HAD AUTHORITY TO USE ITS DEBIT CARD. SIEGEL USED THE FOUNDATION'S FUNDS, TOTALING MORE THAN $76,000, FOR HIS PERSONAL BENEFIT. SIEGEL USED THE FUNDS TO REPAY LOANS, PAY HIS CHILDREN'S SCHOOL TUITION, AND PAY PERSONAL LIFE INSURANCE POLICY PREMIUMS, WITHOUT INFORMING OR SEEKING PERMISSION FROM FOUNDATION OFFICERS OR BOARD MEMBERS. AFTER SIEGEL'S FIRM DISCOVERED THE CONVERSION, HE REIMBURSED THE FOUNDATION FOR THE EXPENDITURES.
Resolution
Decision & Order of Offer of Settlement
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Start Date
6/17/2014
Regulator Statement
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, SIEGEL CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT HE WRONGFULLY CONVERTED MORE THAN $76,000 OF A FOUNDATION'S FUNDS FOR HIS PERSONAL USE. THE FINDINGS STATED THAT SIEGEL WAS APPOINTED PRESIDENT OF THE FOUNDATION, WHICH WAS ESTABLISHED BY A CUSTOMER'S ESTATE AFTER THE CUSTOMER'S DEATH, AND OPENED A BROKERAGE ACCOUNT AT HIS MEMBER FIRM TO FUND ITS ACTIVITIES. SIEGEL OBTAINED HIS FIRM'S PERMISSION TO SERVE AS PRESIDENT, BUT FIRM POLICIES PROHIBITED HIM FROM RECEIVING ANY COMPENSATION AS AN OFFICER OF THE FOUNDATION AND FROM SERVING AS THE REGISTERED REPRESENTATIVE FOR THE FOUNDATION'S BROKERAGE ACCOUNT. SIEGEL CEASED BEING THE BROKER OF RECORD AT HIS FIRM FOR THE FOUNDATION. AS PRESIDENT, SIEGEL HAD ACCESS TO THE FOUNDATION'S CHECKING ACCOUNT, COULD WITHDRAW FUNDS FROM THAT ACCOUNT, AND HAD AUTHORITY TO USE ITS DEBIT CARD, WHICH BORE HIS NAME. SIEGEL WAS ALSO RESPONSIBLE FOR PLACING TRADES IN THE FOUNDATION'S BROKERAGE ACCOUNT. SIEGEL USED THE FOUNDATION'S FUNDS FOR HIS PERSONAL BENEFIT, AND DID NOT INFORM FELLOW FOUNDATION OFFICERS OR BOARD MEMBERS THAT HE USED FUNDS FOR PERSONAL EXPENSES, NOR DID HE SEEK THEIR PERMISSION PRIOR TO DOING SO. ONLY AFTER SIEGEL'S FIRM DISCOVERED THE CONVERSION DID HE, REIMBURSE THE FOUNDATION FOR THE EXPENDITURES.