According to FINRA, Steven Kent Romjue was fined $5,000 and suspended for six months for causing his member firm to maintain inaccurate books and records by deliberately changing representative codes for trades.

Romjue had entered into agreements through which he agreed to service customer accounts under joint representative codes that he shared with two retired representatives. Each agreement specified what percentages of commissions each representative would earn on trades placed using the applicable joint representative code.

Although the firm's system correctly prepopulated trades with the applicable joint representative code, Romjue changed the codes to his personal representative code or another representative code. He did not ask either retired representative whether he could change the code on the trades and did not otherwise indicate to them that he was doing so. Instead, Romjue incorrectly assumed that the retired representatives agreed with his changing the codes because they did not complain about the commissions they received.

Romjue's actions resulted in his receiving higher commissions from the trades than what he was entitled to receive. The firm subsequently paid restitution to the retired representatives, and Romjue reimbursed the firm $182,232, which was the approximate amount of additional commissions he improperly received.

Unlike some representative code cases that involve negligence, Romjue's conduct involved deliberately changing the codes. His assumption that silence constituted consent was unreasonable, particularly given the substantial amount of commissions at issue. The unauthorized change of representative codes constitutes falsification of firm books and records.

Accurate books and records are essential for regulatory oversight, firm supervision, and proper commission allocations. Representative codes on trades are used to track production, determine compensation, and monitor for compliance issues. Falsifying these codes undermines record integrity and can impair the firm's ability to supervise trading activity.

Investors should understand that the integrity of firm records is important for investor protection. While this case involved commission allocations rather than direct customer harm, it demonstrates a willingness to manipulate records for personal financial gain, which raises broader concerns about trustworthiness and ethical standards.