According to FINRA, Jonathan William Affe was fined $5,000 and suspended for 15 business days for impersonating a customer during telephone calls with an insurance company.

With the customer's permission and in the customer's presence, Affe impersonated the customer during telephone calls to an insurance company to obtain information concerning the customer's existing variable annuity investment. During the calls, Affe introduced himself to the insurance company as the customer by name and used the customer's personal identifying information for authentication purposes.

The particularly concerning aspect of this case is that Affe engaged in this conduct after receiving a warning from FINRA that impersonating customers violates FINRA rules. Despite this prior warning, he continued the practice. During one of the telephone calls, a representative of the insurance company stated that she had reason to believe Affe was impersonating the customer. Rather than acknowledging the truth, Affe repeated his claim that he was the customer and ended the call.

While Affe may have believed he was helping the customer by obtaining information more efficiently, impersonation is prohibited because it undermines the security measures that companies have in place to protect customer information and accounts. It also involves dishonesty and misrepresentation.

Even with customer permission, impersonation is not appropriate. The proper procedure is for the customer to contact the company directly or to provide written authorization for the broker to act on their behalf. Insurance companies and other financial institutions have security procedures requiring verification of identity before releasing information, and these procedures exist for customer protection.

The fact that Affe continued to impersonate customers after receiving a prior warning from FINRA demonstrates a disregard for regulatory guidance and a willingness to engage in dishonest conduct even after being told it was prohibited. The relatively light sanction may reflect that the conduct was done with customer permission and in the customer's presence, but it still constituted a violation warranting discipline.

Investors should never give brokers permission to impersonate them when contacting financial institutions. Such practices undermine security procedures designed to protect accounts and can create opportunities for unauthorized activity.