Tracy Michelle Lund of Hillsborough Oregon a stockbroker formerly employed by Key Investment Services has been barred from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon findings that Lund failed to cooperate in a FINRA investigation into allegations of her suspicious transactions involving a customer’s account. Letter of Acceptance Waiver and Consent No. 2018058860601 (Oct. 19, 2018).
According to the AWC, Lund had been terminated from Key Investment Services LLC on June 13, 2018 while under the firm’s investigation for the transfer of funds from Lund’s account into the account of a brokerage account controlled by a customer. Apparently, when Lund was questioned about her activities involving the customer’s account, she resigned from the firm, precluding the firm from determining whether Lund engaged in violative activities.
The AWC stated that an investigation was launched by FINRA subsequent to Lund’s termination, where the regulator sought information from Lund in regards to the basis behind Key Investment Services terminating Lund’s registration. On July 18, 2018, correspondence was sent to Lund by FINRA under Rule 8210, which called on Lund to provide information to the regulator no later than August 1, 2018.
The AWC stated that Lund failed to respond to FINRA’s first request, prompting FINRA send Lund another written request for Lund’s information. Again, Lund failed to cooperate with the request, providing nothing to FINRA by the August 20, 2018 deadline. Rather, Lund’s legal counsel contacted FINRA on September 5, 2018, revealing that although Lund understood the nature of FINRA’s request, Lund would a no point be providing a response to FINRA’s request for information. FINRA found that Lund’s conduct was violative of FINRA Rules 2010 and 8210.
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