According to FINRA, Randell James Ogden was fined $7,500 and suspended for 15 business days for improperly directing the removal of non-public personal customer information from his member firm without the firm's or customers' knowledge or consent.

In anticipation of joining another FINRA member firm, Ogden directed a firm representative who reported to him to remove non-public personal customer information from the firm. The representative sent to his personal email address and to a drive external to the firm encrypted documents containing non-public information of over 200 firm customers. This information included dates of birth, driver's license numbers, and social security numbers. Ogden and the representative subsequently resigned from their firm and joined the new firm the same day. The non-public personal information was used to populate a separate customer information database for use at the new firm.

Prior to resigning, Ogden also directed the representative and another employee to obtain pre-filled new account packets to be sent to existing firm customers to transition them to the new firm. These packets also included customer non-public personal information. At Ogden's direction, the other representative saved these pre-filled forms on the drive external to the firm. Ogden then distributed the pre-filled forms to customers using email and physical mail once he registered with the new firm.

This case involves aggravating factors beyond simple unauthorized removal of customer information. Ogden directed subordinates to take the information, used it to populate systems at his new firm, and actually distributed the information to customers. The involvement of over 200 customers' sensitive personal information created substantial privacy and security risks. Registered representatives must follow proper procedures for customer transitions and cannot misappropriate firm property or customer information.