The United States Financial Industry Regulatory Authority (FINRA) on Friday announced the imposition of a fine and a short-term suspension on Daniel Hee, a former General Securities Representative of UBS Financial Services Inc. The sanctions form part of a settlement proposed by Daniel Hee which FINRA has determined to accept.
The settlement concerns rule violations committed by Hee between November 2015 and January 2016.
In particular, in the period between November 2015 and January 2016, while he was still registered through an association with UBS, and in anticipation of moving to a new firm, Hee printed account documents for approximately 100 customers and hand-delivered them to a representative he planned to work with at the new firm.
The documents he delivered included non-public personal information (NPI), such as social security numbers, birth dates, and account numbers, which was information provided to UBS by those customers. Hee improperly removed the customers’ documents containing this information and gave them to a representative at the new firm without UBS’s or the customers’ knowledge or consent.
The documents Hee removed were never uploaded to the new firm’s system and were not used to recruit any customers away from UBS.
FINRA explains that Regulation S-P generally prohibits financial institutions from disclosing NPI about a customer unless the customer receives proper notice and opportunity to opt out. A registered person who discloses a customer’s NPI, and causes his or her member firm to violate Regulation S-P, violates FINRA Rule 2010, which requires registered persons to observe high standards of commercial honor and just and equitable principles of trade.
As a result of his conduct, Hee caused UBS to violate the SEC’s Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Personal Information (Regulation S-P) and, in so doing, Hee violated FINRA Rule 2010.
Hee has agreed to a suspension from association with any FINRA member firm in any and all capacities for a period of ten business days, and a $5,000 fine.