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Ka Kiertonkaysy Lor, of Sacramento, California, a registered representative with Farmers Financial Solutions, was charged by Financial Industry Regulatory Authority (FINRA) Department of Enforcement in a Complaint alleging that she converted customers’ funds. Department of Enforcement v. Lor, No. 2014041073501 (Apr. 7, 2016).
According to the Complaint, in October 2013, Lor, an insurance agent who was in the business of selling various casualty, life, and property insurance policies to customers, took possession of several customers’ insurance premiums, but had not applied such funds towards the customers’ insurance premium payments as she was obligated to do. Rather, Lor apparently used the funds to address expenses associated with paying her staff and covering the rent associated with her office.
The Complaint stated that in January 2014, funds coming from an estimated thirty-four customers had been converted by Lor. Lor apparently used the thirty-four customers’ funds to pay other customers’ premium payments to account for her previous conversion of the other customers’ funds. FINRA found that Lor’s conduct was violative of FINRA Rule 2010.
FINRA received notification from Farmers Financial Solutions on May 2, 2014, that Lor was terminated on May 1, 2014, in connection with allegations that she improperly utilized customer insurance premium payments. Subsequently, FINRA launched an investigation into Lor’s misconduct, pursuant to Rule 8210, and requested that she provide documents and information in connection with such allegations by September 14, 2015.
The Complaint alleged that Lor ultimately failed to provide FINRA with information and documentation that they requested, including tax return information, by FINRA’s imposed deadline. FINRA alleged that Lor violated FINRA Rules 2010 and 8210 in this regard.
Additionally, the Complaint indicated that Lor was sent a FINRA request on December 2, 2015, per Rule 8210, to provide on-the-record testimony before FINRA in connection with the aforementioned allegations. Apparently, FINRA received notification on December 2, 2015, that Lor would not be providing such testimony at any point.
The Complaint indicated that FINRA made a final attempt at procuring Lor’s testimony on December 11, 2015, and was again informed by Lor that she would not be participating in the investigation. The Complaint stated that Lor never provided such testimony. FINRA alleged that Lor violated FINRA Rules 2010 and 8210 as a result.

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