Tiffany Lea Chamberlain (CRD #4204733, Registered Principal) submitted an Offer of Settlement in which she was fined $7,500 and suspended from association with any FINRA member in any capacity for six months. The suspension is in effect from January 22, 2013, through July 21, 2013. See FINRA Case #2011026351101. Chamberlain was registered with FINRA at Morgan Keegan & Company, Inc., from August 2008 to February 2011.
Without admitting or denying the allegations, Chamberlain consented to the described sanctions and to the entry of findings that an affiliate bank of her member firm issued her a credit card to be used for legitimate business of the affiliate only, and was not to be used for personal charges under any circumstances. The findings stated that Chamberlain, on separate occasions, attested that she had read the affiliate’s Code of Conduct, which stated that proper use of corporate assets is her responsibility and must not be used for personal use, and completed the affiliate’s business ethics training, which required reviewing the Code of Conduct.
The findings also stated that Chamberlain knew that the affiliate’s policy prohibited her from using her corporate-issued credit card for personal expenses. Nonetheless she repeatedly used the credit card to make cash withdrawals from automated teller machines (ATM) and improperly used the proceeds to pay for her personal expenses. Chamberlain used her corporate-issued credit card numerous times to improperly withdraw approximately $40,342 in cash to pay for personal expenses, in violation of the affiliate’s policies, notwithstanding the fact that she typically paid her credit card bill in full on or near the due date. Chamberlain improperly paid for personal expenses using the proceeds of the cash withdrawals made with her corporate credit card.
The findings further included that Chamberlain never obtained permission from her firm or its affiliate to use the affiliate’s funds to pay for personal expenses. Chamberlain used the withdrawn funds in a manner she was not authorized or entitled to use them, and knowingly violated the affiliate’s policies she had accepted and acknowledged as part of her association and as a condition of being issued the credit card.
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