Respondent outsourced complaint handling in 2017.

She stated that she acted on instructions from her supervisor.

Defrauded and bankrupt rep “largely the architect of her current financial misfortune.”

Order execution only firm agrees to pay more than $8.8-million for recommending investments.

Terms not disclosed when rep, known to regulators, attempts to retain control of his firm.

Also sanctioned for borrowing $30,000 from another client and for misleading firms.

Hearing panel notes that form violations are shrinking as a percentage of files opened.