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Commingling of client funds is often a first step that eventually leads to misappropriation of client funds (it’s a gateway drug, err, violation). In order to misappropriate funds, one needs to have them in their possession first (wait, that does sound like drugs), which is how commingling funds figure into this.
Misappropriation is the misappropriation of client funds, or when a member firm uses client funds in an inappropriate or unauthorized way. Under FINRA Rule 3070, member firms m...
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