The allegations read: Without admitting or denying the findings, nia consented to the sanctions and to the entry of findings that she effected unauthorized transactions in a community bank account, which was her member firm customer, without obtaining instructions from any person authorized to conduct trading for the bank. The findings stated that nia accepted orders for the bank's trading from a firm registered representative who was not authorized to place orders for the bank and permitted him to place orders for the bank. As an advisory board member for the bank, the other representative was not authorized to accept or place securities orders for the bank's accounts due to the conflict of interest posed by his affiliation with the bank and the firm. The trading effected by nia, based upon instructions from the other representative, caused the bank to take excessive risk. The trading for the bank generated approximately $1 million in commissions for nia, more than $370,000 of which she transmitted to the other representative through a series of separate business and financial transactions. Because the firm lacked its own fixed-income trading desk, it was frequently required to use a "broker's broker" to acquire fixed income securities for the bank, which resulted in it paying approximately $1.25 million in markups to the broker's broker, in addition to commissions to the firm. As a result of this trading, the bank also spent more than $600,000 to remediate the risk of its investment portfolio.
