Richard Alan Seligson (CRD #3169733, Registered Representative, Boca Raton, Florida)
submitted a Letter of Acceptance, Waiver and Consent in which he was fined $10,000, suspended from association with any FINRA member in any capacity for one year and ordered to pay $41,100, plus interest, in restitution to customers. The suspension is in effect from December 17, 2012, through December 16, 2013. See FINRA Case #2011029460101. Seligson recently was registered with National Securities Corporation and Morgan Stanley Smith Barney.
Without admitting or denying the findings, Seligson consented to the described sanctions and to the entry of findings that he borrowed $45,000 from close friends and relatives, all of whom were his firm’s customers. The findings stated that Seligson has repaid only $3,900 of the amount owed. Seligson did not seek to obtain his firm’s written approval to obtain loans from any of the customers. Seligson completed compliance questionnaires in which he was asked if he had entered into loans with customers. On each questionnaire, Seligson falsely answered that he had not taken such loans. The findings also stated that the firm’s written supervisory procedures (“WSPs”) generally prohibited representatives from taking loans from their customers, except under extremely rare and extenuating circumstances. Under the firm’s procedures, these circumstances could include borrowing or lending arrangements with clients who were family members. The firm’s WSPs explicitly stated that requests to enter into borrowing or lending arrangements with family members had to be submitted for review and approval before engaging in lending activity.
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