3.4  Practical Application

From the day she was initially hired, Amy Adams had a healthy respect for Matt the Branch Manager. He was a dedicated manager who valued the integrity of his team as much as he did the growth of their business. Amy was certain that Matt was where the buck would always stop at her firm.

That was until she got a cease and desist order from her state’s securities administrator. The order, which requested that she cease all securities-related activities immediately, made Amy’s heart sink when she first read it. This meant she would not be able to work at the job she loved so much and that she would not be paid for her services. Apparently, someone in the administrator’s office discovered that Amy’s Social Security number had already been used to register another professional in her state. In fact, the professional that apparently had the same Social Security number had her registration revoked five years prior due to substantial ethical and legal violations.

Included in the letter was a copy of Amy’s application for registration and a request that Amy provide any additional information that might clear up this matter, along with copies of various forms of identification and the paperwork she completed with her firm at the time she was hired. As Amy reviewed the information with Matt the Branch Manager, she noticed that the Social Security number on her application was not in fact her Social Security number, but that one digit had been incorrectly entered.

At this discovery, Matt breathed a sigh of relief. He told Amy Adams to take the rest of the week off and that the firm’s compliance department would supply the needed information to the administrator and ask for an interpretive opinion. He promised to have a couple of the firm’s top advisers cover Amy’s accounts while the mess got sorted out.

Less than a week later, Amy received her interpretive ruling from the administrator. The ruling stated that Amy had