Cynthia Bolker, of San Diego, California, a stockbroker formerly registered with NYLife Securities LLC, was permanently barred from associating with any Financial Industry Regulatory Authority (FINRA) member firm in any capacity after consenting to findings that Bolker engaged in unauthorized borrowing arrangements with customers, and falsified statements to her firm and FINRA concerning such. Letter of Acceptance, Waiver and Consent, No. 2015044753401 (Nov. 16, 2016).
According to the AWC, from June of 2010 and July of 2015, approximately $745,800.00 was borrowed by Bolker from ten of the firm’s customers. The monies, which were utilized for addressing Bolker’s personal expenses, had been accumulated over a series of thirty-seven transactions. The AWC reported that at least two of the individuals that Bolker had solicited were NYLife Securities customers.
Apparently, the firm was never provided information from Bolker regarding such borrowing arrangements. NYLIFE Securities reportedly prohibited customers’ funds from being borrowed by registered representatives. As such, FINRA found that Bolker’s conduct of borrowing funds from customers was violative of FINRA Rules 2010 and 3240.
The AWC also reported that Bolker made misleading and false statements concerning her borrowing arrangements with customers in the course of an internal investigation conducted by New York Life Insurance Company as well as NYLife Securities. Specifically, on September 23, 2015, and several occasions thereafter, Bolker apparently claimed that she never borrowed monies from customers of NYLife Securities. FINRA stated that Bolker knew that her remarks were false, and found that Bolker’s conduct was therefore violative of FINRA Rule 2010.
According to the AWC, in November of 2015, FINRA requested that Bolker provide information and documentation concerning the loan arrangements, per FINRA Rule 8210. Apparently, Bolker’s December 2015 responses to FINRA were void of documentation of loans pertaining to the NYLife Securities’ customers, and did not address several of the items that FINRA requested, including bank statements, and other information concerning borrowing arrangements.
The AWC also revealed that Bolker reiterated to FINRA that her remarks within her firm’s internal investigation were truthful, when FINRA established that such statements made by Bolker were false. FINRA found that Bolker’s conduct of providing incomplete, misleading, and false information to FINRA was violative of FINRA Rules 2010 and 8210, leading to her bar.
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