According to FINRA, Matthew Allen Trueg was fined $5,000 and suspended for two months on March 31, 2022, for affixing customer signatures on account forms without authorization.
Trueg copied customer signatures from older forms customers had previously signed and pasted them onto forms requiring updated customer signatures. He then submitted the altered forms to his firm to complete transactions customers requested. There is no indication that Trueg affixed the signatures without customers' consent to the underlying transactions. Each customer later re-signed the documents.
Some of the account documents were new account agreements and authorizations, which were firm records. By engaging in this conduct, Trueg caused the firm to maintain inaccurate books and records.
While this case appears less egregious than outright forgery cases because customers had requested the underlying transactions and later re-signed the documents, affixing signatures without authorization is still prohibited. The practice creates risks even when done with good intentions.
Signatures serve as evidence that customers reviewed documents, understood their contents, and agreed to the terms. When representatives affix signatures, even using copied signatures from prior documents, customers are denied the opportunity to review current documents before signing. Documents may contain terms, disclosures, or information that differs from prior versions.
Additionally, the practice creates compliance and legal risks for firms. Documents bearing signatures that customers did not personally apply may be challenged later, creating disputes about whether customers actually authorized transactions or agreed to terms.
The appropriate practice when customers need to sign documents is to present the actual documents for signature, even if this creates some inconvenience or delay. Technology solutions like electronic signature platforms can streamline this process while ensuring customers actually review and sign documents.
This case demonstrates that representatives cannot take shortcuts with signature requirements, even when trying to expedite transactions customers requested. The integrity of the signature process must be maintained to protect both customers and firms.