Fine Amount: $177,962.80
Primary Violation: Conversion and Failure to Provide Testimony
Relevant Period: Nov-2022 > Apr-2023
Overview
FINRA accepted an offer of settlement from Andrew Buckanavage, a former registered representative with Allen, Mooney & Barnes Brokerage Services, LLC, barring him from associating with any FINRA member firm.
The action stems from Buckanavage's conversion of $177,962.80 in employer funds through unauthorised personal charges on a corporate credit card and his subsequent failure to appear for on-the-record testimony requested under FINRA Rule 8210 during the investigation.
Andrew Buckanavage, registered with FINRA since 2018 as an Investment Banking Representative through Allen, Mooney & Barnes Brokerage Services, LLC (AMBBS), was employed by both AMBBS and an affiliated private equity firm. In October 2022, the affiliated firm issued him a corporate credit card strictly for business expenses, as per his employment agreement and firm policies. Employees were required to annotate monthly expense reports with details of charges, and any personal use had to be reported for reimbursement via payroll deduction or direct payment.
Between November 2022 and April 2023, Buckanavage misused the card to charge personal expenses totaling $177,962.80, either by transferring funds via PayPal to his personal account or direct charges, without authorization. He submitted false expense reports misrepresenting these as business expenses or failing to disclose their personal nature.
When questioned in April 2023, he initially provided false explanations before admitting the misconduct on May 4, 2023, leading to his resignation on May 23, 2023. FINRA's investigation, initiated in June 2023, requested documents and testimony under Rule 8210, but Buckanavage failed to appear for scheduled testimony on May 8, 2024, and June 11, 2024, impeding the probe.
Buckanavage transferred $2,469.90 from his corporate credit card to an intermediary PayPal account created with his firm email, then to his personal PayPal for non-business use; this was part of 94 such transfers totaling $176,839.62, misrepresented as business expenses.
A transfer of $7,512.00 via the same PayPal method for personal expenses; this was the largest single transfer in January, amid multiple daily transfers aggregating over $20,000 that month.
Charged $391.85 for "Paper, binders and presentation materials," but it was personal; one of 12 direct charges totaling $1,123.18, including meals and a hotel stay.
Bar from associating in any capacity with any FINRA member.
"Conversion is an intentional and unauthorized taking of and/or exercise of ownership over property by one who neither owns the property nor is entitled to possess it."
"Buckanavage intentionally and without authorization took the Affiliated Private Equity Firm’s funds for his own personal benefit."
"By failing to appear for testimony as requested pursuant to FINRA Rule 8210, Buckanavage violated FINRA Rules 8210 and 2010."