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Regulation and Compliance > Federal Regulation > FINRA

FINRA Fines Former LPL Rep for Faking 30 Clients’ Signatures

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The Financial Industry Regulatory Authority fined a former LPL Financial broker $5,000 and suspended him for four months from associating with any FINRA member in any capacity after he “forged or falsified the electronic signatures” of 30 clients on 53 account documents, according to the regulator.

Without admitting or denying the regulator’s findings, Cody Robert Roos signed a FINRA letter of acceptance, waiver and consent on Sept. 20 in which he consented to the sanctions.

Andrew Friedman, principal counsel for the FINRA Department of Enforcement, signed the letter on Thursday, bringing the disciplinary action to a close.

LPL did not immediately respond to a request for comment on Tuesday.

Why it matters: A large number of brokers have received the same or similar sanctions from FINRA for the same or similar violations.

Signing forms on behalf of clients often saves time for the broker and the client.

But FINRA explains: “Falsifying documents occurs when a person creates a document or entry in a firm’s system that creates a false appearance by including altered or untrue information. Signing or affixing another person’s name to a document with the other person’s prior permission but without indicating that it is being done on someone else’s behalf is falsification.”

Falsification is a violation of FINRA Rule 2010. Additionally, a general registered representative who “falsifies firm records causes the firm to maintain inaccurate records and, thereby, violates FINRA Rule 4511,” the regulator points out.

What to know: From December 2018 through November 2021, Roos forged or falsified the electronic signatures of 30 clients on 53 account documents, according to FINRA.

Roos first registered with FINRA in 2016. In October 2018, Roos became registered as a GSR through an association with LPL, according to FINRA.

LPL terminated Roos’ registration in a Form U5 termination notice dated Jan. 11, 2022, disclosing that the broker left the firm voluntarily.

In an amended Form U5 dated Feb. 11, 2022, LPL disclosed that Roos resigned while he was under internal review for electronically signing his clients’ names.

Roos is no longer associated with any FINRA member and is no longer a registered broker, according to his report on FINRA’s BrokerCheck website. But he is still registered as an advisor.

Looking ahead:  The sanctions imposed in an AWC letter become effective on a date set by FINRA.

When a broker accepts FINRA’s sanctions and signs an AWC letter, the regulator, for its part, agrees that it will not bring any future actions against the broker alleging violations based on the same factual findings described in the letter.


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