Sam M. Stull, a registered representative for J.P. Morgan Securities LLC, was permanently barred from association with any Financial Industry Regulatory Authority (FINRA) member firm in all capacities after consenting to findings that Stull forged the signatures of several customers and failed to cooperate with FINRA in their investigation into allegations of Stull’s misconduct. Letter of Acceptance, Waiver, and Consent, No. 2014042589601 (Mar. 30, 2015).
According to the AWC, from January, 2014 – June, 2014, Stull forged the signatures on eighteen customers on thirty-one of the firm’s documents. The AWC indicated that the forged documents had included investment switch letters, account profile confirmations, and beneficiary information sheets. The firm’s written supervisory procedures, according to the AWC, required that the signatures had to be original and that registered representatives such as Stull were prohibited from forging a client’s signature in any manner. FINRA found Stull’s conduct in this regard to be violative of Rule 2010.
The AWC further noted that in January, 2015, FINRA had requested information and documentation from Stull in furtherance of their investigation into Stull’s conduct, pursuant to Rule 8210. Stull’s counsel eventually informed FINRA’s staff that Stull was not going to cooperate with their request for information and documentation.
FINRA registered representatives like Stull who do not cooperate with FINRA’s investigations often face a permanent bar from practicing in the securities industry as such lack of cooperation violates FINRA’s Rule 8210 – requiring that no member or person shall fail to provide information or testimony or permit an inspection and copying of books, records, or accounts pursuant to the rule. FINRA typically accompanies a Rule 8210 violation with a Rule 2010 violation when individuals, according to FINRA, do not appear to observe high standards for commercial honor and just and equitable principles of trade.
Public disclosure records reveal that Stull was subject to two customer disputes prior to his permanent bar from FINRA. On October 7, 2014, Stull settled a customer dispute after a client alleged that a signature on an account profile confirmation form was not authentic. On November 25, 2014, Stull settled a customer dispute with a client after the client alleged that the signature on switch forms and a standing instruction form was not authentic.
Firms and individuals, not surprisingly, are prohibited from unauthorized use of customer funds, borrowing of a customer’s securities or funds, forgery, non-disclosures or misstatements of material facts, and various deceptions and manipulations. Such conduct can also be found to violate criminal and other civil laws, and be subject to sanction from the federal and state government bodies.
Guiliano Law Group
If you have been the victim of securities fraud and you have a complaint, you should consult with an attorney. The practice of Nicholas J. Guiliano, Esq., and The Guiliano Law Group, P.C., is limited to the representation of investors in claims for fraud in connection with the sale of securities, the sale or recommendation of excessively risky or unsuitable securities, breach of fiduciary duty, and the failure to supervise. We accept representation on a contingent fee basis, meaning there is no cost unless we make a recovery for you, and there is never any charge for a consultation or an evaluation of your claim. For more information contact us at (877) SEC-ATTY.
