In January and February 2015, FINRA’s Department of Enforcement initiated an investigation into Stull’s business dealings to ascertain whether he forged his clients’ signatures on JP Morgan documents. FINRA alleges Stull forged the signatures of 18 customers on 31 JP documents from January 2014 to June 2014. In connection with this investigation, FINRA sent Stull a request dated February 4, 2015, seeking documents and information for the investigation. According to FINRA, Stull acknowledged receipt of FINRA’s Rule 8210 request and informed staff he would not cooperate with FINRA’s investigation.
Based upon the foregoing alleged misconduct, FINRA asserted Stull violated FINRA Rules 2010 and 8210. Specifically, FINRA Rule 8210 authorizes FINRA, in the course of its investigations, to require persons associated with a FINRA member to “provide information orally, in writing, or electronically . . . with respect to any matter involved in the investigation...” Here, Stull failed to provide testimony in response to FINRA’s request, thereby violating FINRA Rule 8210. FINRA has very little tolerance for uncooperative members and promptly barred Stull from the financial industry.
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