Introduction — A Coroner’s Report

Death is never a pleasant subject, no matter how tragic or ennobling it might be to those left behind to contemplate its significance. There are occasions, however, in which it is in the public interest to investigate into a death, to determine its cause or the contributing causes and to make recommendations for the prevention of future deaths.

So it could be said that this is a coroner’s report, an inquest into a wrongful death, although, mercifully, not in any literal sense. The subject of this piece has not died physically, although the hardships she has had to endure would have led many a weaker soul to the brink of suicide. But death has many faces, and the one which will present itself, if not dire, necessarily, is an ugly one nonetheless: the death of a promising career.

The career which has passed away belonged to a stockbroker, or Investment Advisor (IA) as brokers are known in the industry, at HSBC Securities in Victoria, British Columbia. As will be evinced, it is difficult to point to any one specific cause of death, but there is no question that it was a homicide. This IA’s career was cut short, gunned down, stabbed in the back and garrotted with piano wire by the financial mafia, a.k.a. the HSBC Group and its henchmen at the British Columbia Securities Commission (BCSC).

Signs of the Times

No thoughtful person can deny that we are living in a time of corporate and government corruption which, if not unprecedented, is certainly being exposed with greater frequency than ever before. Graft and cronyism might be the grease on the wheels of commerce, but society seems to know when the grease is threatening to leave too large a trail. Which is to say that there is business which is dubiously conducted in the dark, with a black bag and a furtive glance, as it were, and then there is corporate and state criminality. Only a moral cretin can fail to see the distinction.

It has been said that the law is the handmaiden of justice. It is equally true—and glib, perhaps—that corruption is the handmaiden of death. Many of our institutions have become distinctly malodorous, unable to mask the stench emanating from out their pores as though from a rotting corpse. The federal government alone provides a multitude of examples, from “Sponsorgate” to “The Grand-Mere Affair”. All but forgotten is the “Billion Dollar Boondoggle” at the Ministry of Human Resources and Development, and the ill-conceived money pit, which passes for a national gun registry. Ad infinitum et ad nauseum.

But these examples belie that it is in fact the nature of corruption to be insidious; generally, it tends to avoid exposing itself to the light. Indeed, if libertarians are to be credited—and their prescience in this regard cannot be gainsaid—the state and its institutions are even more corrupt than the most reckless averments of the most pointy-headed conspiracy theorist could have suggested. We need not look far to find a case study, which would illustrate this assertion; indeed, would show it to be a truism. Like the ether it is unperceived and yet it is all around us. It does not even have a name, or rather, its name is Legion; it is generally referred to under the rubric “the financial services industry”.

There are many indicia of institutional corruption: turning a blind eye can be one, padding invoices can be another. They can be sins of omission as well as of commission. The hallmark of corruption, however, is unaccountability. In the financial services industry this unaccountability is built right into the system, as it is whenever the government cedes a portion of its authority to an unelected administrative body. In exchange for expertise, some professions are given the right to regulate themselves. Often, however, these deals made on behalf of electors assume the character of pacts entered into with the devil. The notion that these regulatory agencies, staffed by members of the profession they purport to regulate, are the legitimate guardians of the public trust and will in every instance act with utmost good faith, has become so naïve a point of view as to be laughable.

The case study, which is the subject of this coroner’s report, proves in spades that our trust in the financial regulators is misplaced. Our case is of an honest stockbroker (IA) who acquiesced in the death of her career for the sake of a client. She remains the only known case of an IA with the intestinal fortitude to clash with the financial mafia which controls the banking and investment industry. For the purposes of this report, and out of respect for the demise of her career, only her first name will be used in what follows: Marcia.

An Honest Broker

Marcia came into the brokerage business through the side door, as it were, of the HSBC Group, a British-owned banking and investment conglomerate whose head office for its Canadian operations is located in Vancouver. Her career in the financial services had already been a lengthy one; first she was a banker, then a Certified Financial Planner (CFP), both for many years. She was initially hired by HSBC Bank as a Manager of Investment Services (MIS), the scope of her duties encompassing financial planning and mutual fund sales to customers of the bank’s branch at Fort Street in Victoria.

Less than two years into her tenure, however, the powers that be (and at the HSBC Group these were said to reside in Olympian aloofness somewhere in London, England) determined that some drastic cost-cutting measures were in order. Profit is one thing, after all; maximizing profit is often quite another. Marcia was duly informed that the MIS program was to be phased out; she and her colleagues would have to become qualified as Investment Advisors (I.A.s) if they wished to remain employed with the Group. For their parts, the existing brokers were ordered to obtain their CFP licenses, although the alacrity with which this order was enforced left much room for suspicion. It seemed to be primarily those in the MIS program who were on the chopping block. The explicit goal of this agenda was to reduce the number of employees performing investment services in one form or another by two thirds.

The means chosen to achieve this end naturally involved various types of attrition. The requirement that I.A.’s must also be CFPs was an example of this; there was no sound business reason which could be gleaned from joining two disparate professions in one person. It was simply a way of culling the herd, and in the process, perhaps, instilling a sense of ruthless ambition in those who would be fortunate enough to emerge from the probationary period with jobs.

Ironically, it was this very requirement which would come back to bite the executive at HSBC Group in the backside in the months to come.

Many in the MIS program were not even allowed the opportunity to meet the new stringent educational criteria; the branch managers, whose own interests were at stake in the restructuring, simply pushed them out. One MIS or two refused to play the game at all and simply moved on under his own steam.

Her bosses probably believed that Marcia would be one of those who would fail to make the cut. She had already evinced a certain independence of mind, and would not be likely to play a game that was rigged from the outset. That someone might enjoy being a broker for the love of the job was beyond the ken of the likes of HSBC Group’s executive. Unscrupulousness in the pursuit of high standards can be controlled by such simple stratagems as money. Incorruptibility, on the other hand, is a perpetual wild card. But that is to give too much credit to HSBC’s honchos. It is doubtful, at this point, that Marcia had been earmarked for summary dismissal. It is more likely that she was not given a second thought.

Certainly she was naïve in many ways. She assumed, for instance, at least in the beginning, that there was nothing whimsical in the resolutions coming down from the executive at HSBC Group. Just as her stock market acumen would be underestimated, she would fail to comprehend for some time the allure of the profit motive on the part of her bosses. Money was venerated in these circles like a god.

The sanctity of money to these people became clear to her for the first time at the “graduation” meal she and her fellow rookies were treated to upon completion of the ninety day training period. The handful of planners who had survived the ordeal were lauded by management as the “cream of the crop”. In other words, just to make it as far as they did meant they had the potential to make a thirsty band of cutthroats indeed.

But Marcia was always cognizant of not fitting in entirely, that she was unlike most of the other newbies. For one thing, she seemed to be the only one to make it through training with her conscience still intact. She was sure, either owing to greed or to cowardice that not one of her colleagues would fail to sacrifice his soul on the altar of profit if the occasion ever presented itself. On the other hand, she genuinely enjoyed being a stockbroker. She resolved, therefore, that though she had been thrust into a pit of snakes she would take a full measure of satisfaction in providing quality service to her clients.

Always adept at getting to the essences of things, she was astute as well in quickly determining what would be required of her in her new profession. She found that ethically she could not go far wrong if she subjected all the advice she gave her clients to the “mother test”. This meant that with every trade she asked herself if she would follow the same course if it were her mother’s money she was handling. She accorded the mother test the highest esteem as her most trustworthy guide, and which summed up for her the CFP code of ethics as concisely as the golden rule encapsulates the Ten Commandments.

Idealism Confronts Reality

It was a daunting task, like Serpico’s in staying off the take, keeping herself free of the taint of dishonesty with which all the veterans at HSBC Securities seemed to be marked. During her probationary period, for instance, she often heard the phrase “churn ‘em and burn ‘em” used to describe the ordinary business practices of the established IAs at her firm. For the uninitiated, “churning” is a term of art which describes the practice of making trades on a clients’ account for no other purpose than to earn more commission. There is uniform disapproval of churning, not only by the regulators, but by the firms themselves. There is also, however, widespread disingenuousness in this regard. Every firm uses a “grid” system for determining an IA’s rate of compensation, which all but ensures that those who earn the highest commissions from their books of business, and if it is by churning, so be it, are most amply rewarded.

Marcia and her fellow rookie IAs found it humorous, in a grim sort of way, that the established brokers at HSBC Securities seemed incapable of earning an honest living. She had not yet realized that the system itself virtually mandates a certain degree of corruption. One is reminded of a line delivered by Denzel Washington in “Training Day”: “You gotta have a little dirt on you for anybody to trust you.” This certainly describes the mores of those with whom she would now be sharing offices; and churning was merely a symptom of a larger disorder, a more virulent disease. The entire industry was afflicted.

It is worthy of note that it was the regulators, not the firms, who established the ninety-day training criterion for rookie IAs. The firms were duty bound on pain of sanctions to provide this training, and they fulfilled their duties as wholeheartedly as if they were forced to eat dung. Those requirements, which were deemed too burdensome, such as having a fledgling IA “shadow” a veteran broker, were simply ignored.

The collective attitude of the established brokers towards compliance issues, and by extension towards customer service, was beyond cavalier. One of these veterans used to make the preposterous claim to prospective clients that “he never lost money for his clients.” Nor was the office manager any more ethical. The wealthiest client whom Marcia had brought over from the bank was not only stolen from her, but her manager then proceeded to lose money on company shares he had purchased on the clients’ account that he, the manager, had been expressly instructed not to buy.

When a fledgling IA is still in training she is prohibited by the securities regulations from making trades on her own. Consequently, a day came when Marcia was obliged to have her manager process some mutual fund purchases. Rather than simply abide by the clients’ instructions he manipulated the purchases in order to “earn” for himself a higher commission. In other words, he churned them. Marcia was finding the taste being left in her mouth by the brokerage business was becoming more unsavoury by the day.

It would be fair to describe the regimen the rookie IAs had just undergone as more a baptism by fire than a ninety day training period. It seemed a little rich, moreover, to be thought of as “the cream of the crop” simply for having survived the ordeal. But Marcia emerged from her probation only to have to endure still more tribulations. All the established IAs eschewed mentoring as nothing more than a species of babysitting; they undertook no activity, which did not have a dollar sign at the end of it.

So her expectations were already low when the branch manager moved on. The firm continued to do business with no one running the office at all for several weeks, a further infringement of securities regulations. With no one supervising the rookies at the Victoria office, Marcia and the others were instructed to contact the “acting” manager in Vancouver if they ever required assistance. When she sought to take this advice, however, her telephone calls were never returned.

By now it was clear to her that if she was ever to learn the ropes she must do so on her own. Much to the future chagrin of the executive at HSBC Group, she carried out her resolution in short order. She spent countless unremunerated hours coming to grips with the machinations of the market and before long had become remarkably adept at spotting the trends; so adept, in fact, that she actually developed her own trading system. She logged onto the Internet at home and began making “trades” on a “play portfolio” she had put together. Before long she was consistently out-performing the “experts”. Clearly, any legitimate securities firm ought to have been thrilled to have landed such an ingenious and industrious rookie advisor.

But when, as in the financial services industry, the inmates are running the asylum, signs of incipient sanity are regarded with suspicion. Qualities such as resourcefulness and honesty are as cancers to such a system; they must be ruthlessly excised lest they be considered the norm. Too much integrity and the system would grind to a halt. Marcia never got a chance to implement her system for real, even though she had clients interested in signing on for it. After thirty years in the business, first as a banker, then as a financial planner, and finally, as an honest broker, her career was shot down, or perhaps more accurately, drowned in an ocean of corruption.

Corruption at the Top

She remembers it well, the day she caught HSBC Asset Management, the subsidiary of the HSBC Group which manages pooled funds accounts for generally wealthy clients, in flagrant delicto. The victim of the malfeasance was a seventy-nine year old widow, another client with whom Marcia had had dealings while she as still an MIS.

It started with a breach of securities regulations, of a sort, which had become routine, and generally attracts a routine fine as a token punishment. A certain portfolio manager at HSBC Asset Management became seized with the compulsion to gamble with the clients’ money as though it was her own. This manager has since left the firm under suspicious circumstances and, indeed, appears to have forsaken the entire industry. What she did was, speculating that the market was poised for a rise, upped the clients’ ante; she unilaterally altered the mandate which the client had signed up for.

There are clear guidelines for establishing and changing investment mandates set out here and there in the forest of securities regulations. They can all, however, be generally subsumed under the “Know Your Client” (KYC) rule. Not surprisingly, this rule dictates that any changes to a mandate are only valid if they are made with the client’s full knowledge and consent. The evidence of such consent would be a duly executed KYC form.

In the case of this elderly widow, perhaps complying with the KYC rule would have taken too long for the market to remain in its presumably advantageous position. Or the manager might have balked at the difficult task of explaining a controversial decision to an unsophisticated investor. Whatever the reason behind the manager’s ignoring the KYC rule, the fact remains that there was no new client signature on any new form. Then the market failed to perform as the portfolio manager expected. Marcia’s client-- as well as every other pooled fund client across the country invested in the same portfolio-- was made to suffer greater losses that she should have.

Nor was this the doing of a rogue portfolio manager. Rather, the decision was clearly taken at the highest levels of Asset Management’s executive. The motivation appears to be of the crassest sort, simple greed, and after the fact, with sheer cowardice.

Predictably, the poobahs at HSBC Group desired to resolve the matter internally, and took the position that the portfolio manager in question had properly exercised her discretion. It was submitted, incredibly, that the client—and by extension all other pooled fund clients invested in the same portfolio-- had authorized the manager to alter the mandates whenever she felt like it, and thus was not liable for the excessive loss.
In a letter to Marcia’s client dated August 27,2001, the Chief Executive Officer of HSBC Asset Management, Stephen Baker, makes these astonishing claims:

As mentioned above, in modifying asset ranges and implementing increased exposure to equities we were carrying (sic) our responsibility of discretionary investment management. These changes while not announced were communicated. The actual increase in equities was shown in the HSBC Pooled Fund Review for Q1/01 dated April 2001, in the section “Model Portfolios for Investors”, copies are provided to investment advisors. You signed an investment management agreement authorizing us to use our discretion within your investment mandate, which is what we have done.

(emphasis added)


In other words, according to this amazing logic, the changes were legitimately made because the clients’ consent was inferred from her being informed of them after the fact. Baker’s assertion, moreover, that the changes were “communicated” to the advisors even though they were “not announced” is either pure unvarnished gobbledy-gook, or a bald faced lie; so too was his incredible statement that in unilaterally upping the client’s ante HSBC Asset Management was acting “within the mandate”.

Ethically, Marcia now found herself at odds with yet another subsidiary of HSBC Bank Canada. Once again she resorted to the mother test and determined her fiduciary duty to her client outweighed the personal interest in maintaining a smooth relationship with HSBC Asset Management. She directed a letter to Stephen Baker dated September 7, 2001 in which she informed him of her duty pursuant to rule 302 of her CFP Code of Ethics, which provides:

Rule 302

A CFP licensee shall offer advice only in those areas in which the CFP has competence. In areas where the CFP licensee is not professionally competent, the CFP designee shall seek the counsel of qualified individuals and/or refer clients to such parties.

Marcia interpreted this rule to mean she was duty bound to refer her elderly client to a lawyer. Indeed, as any lawyer would argue, the words “shall” set out in Rule 302 evince that she had no discretion to do otherwise.
It was beyond dispute that HSBC Asset Management had committed an actionable offence. This client, however, was far more generous to her portfolio manager than she ought to have been and settled for an ex gratia payment to her account, a pittance of what she would have been awarded by a court. The fact remains that she would have had a valid cause of action even if the market had gone up.

That HSBC Group was so anxious to resolve the matter internally is also noteworthy. The executive was well aware it was in a precarious legal position, that if wrongdoing was admitted in one case, the liability would have to accrue in regard to all the other pooled fund clients invested in the same discretionary account across the country.

By the time Marcia wrote her letter the firm had hired a new branch manager, Barry Clark. He called her into his office one day and informed her that “they”, meaning the executive at HSBC Group, “didn’t like her letter.” She was told that if she referred her client to a lawyer or if she got the regulators involved she would be asked to leave the firm. Marcia replied that because she had done nothing wrong she had no intention of leaving. Moreover, Asset Management had itself suggested on a prior occasion that Marcia have a client seek independent legal advice before investing in a pooled fund account. Clark expressed the opinion that she would be given a severance package, his rationale being that she should “not shit where she sleeps”. This from the representative of the firm, which had demanded she maintain her CFP license in good standing. She was now being threatened with the loss of her job if she did not jeopardize her license by wilfully breaking rule 302 of her code of ethics. She was also well aware that the banking regulators also have requirements, such as signing a yearly statement that no malfeasance was witnessed at the branch she was working at, upon which her continued employment was conditional.

If she felt she was rudderless during her probationary period she was now even more adrift. She was floating on a sea of corruption which threatened to engulf her at any moment, and that proved to be even deeper that she expected once she got the regulators involved.

First, she filed a formal complaint report with the BCSC against HSBC Asset Management. Upon hearing the substance of the complaint, the investigator who took her statement made a telling observation. His first reaction was to exclaim that “we could shut them down” if the substance of the complaint was found to have merit, that is, if the firm had committed so egregious an act as to unilaterally alter the mandates on one class of its pooled fund accounts. After all, CIBC is now defending itself against a class action for doing precisely the same thing with certain of its mutual funds.

Marcia also filed concurrent complaints against her own firm, HSBC Securities, for other ethical breaches. One of her colleagues, for example, determined that the pickings for new clients were better if he operated out of the bank branch, even though it was not licensed for him to sell securities. Another IA had failed to comply with the KYC rule before executing a trade for a client.

It seemed to her that the Superintendent of Financial Institutions ought to be interested in how HSBC Bank was being wilfully blind to the goings on at one of its branches in allowing unlicensed securities activities. When she directed a letter to that august body, however, she found its representatives did not want to get within five hundred miles of the stench emanating from he HSBC Group in Victoria. The office of the superintendent refused to exercise jurisdiction; instead, it passed the buck to the Investment Dealers Association (IDA) in British Columbia.

The IDA agreed that it was a serious breach to operate out of an unlicensed bank branch and informed Marcia that the matter would be addressed when the firm was next audited. Her complaint regarding the failure of an IA to comply with the KYC rule, however, disappeared into a bureaucratic black hole. The IDA never even acknowledged receipt of her letter.

The Financial Mafia

In the meantime, the BCSC had concluded its investigation of Asset Managements shenanigans on its pooled fund portfolios. The conclusion, which was arrived at, if ever widely known and disseminated among the investing public, would in all likelihood call into question the BCSC’s very legitimacy. HSBC Asset Management, it was determined without giving reasons, had committed “no clear violation” of securities regulations when it changed the mandate on an entire class of its pooled fund accounts.

The fraudsters received not so much as a reprimand. The clients who lost money were figuratively spat upon by the very agency charged with upholding the public trust. Further, in whitewashing the sins of the portfolio managers, and in suggesting the clients’ losses could be chalked up to a bad day for the market, the BCSC made itself an accomplice to the malfeasance.
It is an open question the degree to which the incestuous relationship between the HSBC Group and Steve Wilson, the BCSC’s executive director, played a role in the plainly erroneous decision. It is certainly fortuitous that prior to his appointment to the regulatory agency’s directorship Steve Wilson was the former President of Hong Kong Bank of Canada Securities, former Vice President of HSBC Asset Management Canada and former Vice President of Hong Kong Bank of Canada.

Make no mistake; what the BCSC had done was a real paint job, a whitewash of the first order. This is proved by the agency’s own audits of pooled fund accounts for the past several years. Not only were infringements of the KYC rule found to have occurred in every year, they were among the five most frequent infractions committed by portfolio managers. In other words, that HSBC Asset Management had violated securities regulations in regard to Marcia’s client was abundantly clear, despite the BCSC’s bogus finding to the contrary. The firms that were audited were even warned that continued flaunting of the KYC rule might well attract civil liability in addition to administrative sanctions for non-compliance.

As if this were not enough, the Ontario Securities Commission (OSC) came to precisely the same conclusion in its annual reports for 2002 and 2003. The OSC also decried the cavalier attitude towards compliance evinced by the firms which were audited, including HSBC Asset Management. Just as with the BCSC’s recommendations, the OSC’s conclusions were treated with almost palpable derision, as though they were idle threats uttered by a feckless schoolmarm. The KYC rule continues to this day to be routinely ignored; new audits are commissioned and the findings presented to the subject firms with a nudge and a wink and an empty promise extracted from them to “do better” in the future.
It cannot be stressed enough that the raison d’etre of agencies such as the provincial securities commissions is the protection of the public interest. This is effected when it can be plainly seen that the financial services industry is operating with the utmost integrity. The reality, however, is just the opposite; the regulators in fact carry out their functions with the most calculated hypocrisy.

The most felicitous comparison -- and this is no hyperbole -- is with organized crime. Advisors like Marcia are regarded as “soldier earners” and are subjected to the most intrusive forms of nannyism by the regulatory bodies. The idea is an old one: throw the authorities a few little fish to fry so that the big ones can continue to operate with impunity. These advisors are so routinely scapegoated that they are not even allowed to purchase error and omissions insurance.

The old boys’ network (and they are always boys), on the other hand, the presidents, vice-presidents, CEO’s, and so on, have the status of “made men”. They even have their own regulators staffed entirely by similarly “made men”. They also have their own “argot”; to use a word of Jean Genet’s in describing the language of the French underworld. Marcia suspects that government is utterly ineffectual in regulating the industry because elected representatives cannot even understand the lingo. It was for this reason alone that the “made men” came to undermine the legitimacy of the regulators' authority.

The irony in all of this-- and it is a bitter one -- is that the only one floating on this cesspool, the only one actually looking out for the interests of investors, are the little “soldier” IA’s like Marcia. It is these individual advisors who bestow any integrity at all upon the system, and who most often take the fall for the ethical failings of the whole profession.

The Unsung Hero

For her part, Marcia never set out to become a hero. She simply did not have a dishonest bone in her body, and was tired of being unable to do her job without daily having to confront the corruption all around her. The mantle of guardian of the integrity of the industry was passed to her in spite of her protestations. But adversity has a way of seeking out the most courageous, and for her heroism she lost everything. Everything, that is, except her soul.

The mucky-mucks at the HSBC Group, after establishing the nearly impossible requirement that Marcia maintain her CFP license in good standing, now sought retribution for her taking her code of ethics seriously. Some of her trailer fees were simply withheld, without explanation, so too were monies which were owed to her pursuant to the short term disability plan she was obliged to resort to when her struggles with the system left her clinically depressed. Then when she sought to assert her contractual rights and demanded to be paid the monies that were owed her, her efforts were construed by the bank’s personnel manager as constituting her resignation. This position is shown to be even more absurd when it is born in mind that Marcia was not even employed by the bank any longer. It can hardly be a coincidence, moreover, that her wrongful dismissal occurred on June 6, 2002, on or about the very day on which Paul Martin’s resignation as Canada’s finance minister was tendered by Jean Chretien.

The vindictiveness and sleaze of the executive of HSBC Group hit new depths when Marcia applied for employment insurance. Her record of employment was deliberately withheld for several weeks so that her claim could not be processed in a timely fashion. Then when the document was finally delivered to the employment insurance commission it contained the libellous assertion that Marcia had resigned her position. The libel had its desired effect and her claim was denied, her premiums disappearing into to $844 billion fund the commission “administers”.

It had been an inferred condition of employment at HSBC Group that any personal debt will be obtained from the employer bank. During the course of her employment, Marcia had on two occasions given mortgages to the bank, one on her home and one on a townhouse she owned as a rental property. Immediately upon her being wrongfully dismissed Marcia put both properties up for sale and in the most shamelessly predatory manner the bank attempted to foreclose on both. They had complete records of her financial status and were well aware her loss of employment meant she would be unable to maintain her payments.

Next, the transfers out of her RRSP’s were inexplicably delayed. The cause of the delay was said to be simple bureaucratic bungling, but it cannot be denied that it was in service of a covert campaign to crush Marcia by any available means. If she did not have enough money even to live on she would be hard pressed, after all, to assert her legal rights and commence an action for wrongful dismissal. Nonetheless, Marcia overcame and her action is currently before the courts.

In the end, though they tried to kill her spirit, they succeeded only in murdering her career. The last straw came when the Financial Planners Standards Council showed itself to be as feckless and two-faced as every other agency charged with regulating the financial services industry. When news reached the council that Barry Clark had advised Marcia to commit a fraud, the branch manager was not sanctioned in any way. When Marcia declared bankruptcy, as she was obliged to do, she advised the Financial Planners Standards council and lost her license until she was discharged from bankruptcy.

Bankruptcy has proven to be an insurmountable obstacle to Marcia’s obtaining other employment as well. One firm after another has remarked upon her impressive credentials, while citing a policy, which prevents them from hiring someone who has gone bankrupt, regardless of the circumstances. The absurdity of such a policy can be readily demonstrated, for it is akin to a doctor being stripped of his medical license because he has had a heart attack.

So in sum, Marcia lost her profession, at which she was earning in excess $120,000 a year; her impeccable credit rating was destroyed, and all her savings had to be liquidated; she lost her home, her rental property, even her BMW; and she lost all her health, life and disability insurance benefits. All of these factors establish that the death of Marcia’s career was indeed a homicide; it cannot be contributed to any natural cause.

It was unavoidable that her reputation would be tarnished, even though it is widely accepted that she was an honest broker. Anytime an IA makes an abrupt disappearance suspicions are bound to arise in the minds of her former clients. No doubt the HSBC Group has invented some kind of cover story to satisfy the more inquisitive.

Marcia’s pride, however, is very much intact, and so too is her conviction that she would do it all over again. Someone has to try. The financial services industry has become a leviathan ever since the banks began their overreaching, a veritable ogre of corruption, consuming anything in its path, including its own rules and regulations, like so much grist for the mill. She has taken a few scars on her soul, but she is proud of them too, because they serve to remind her that she was able to hold onto her soul, though the whole world might have been taken from her.

She intends to get it all back. Her career might have been murdered, but she herself is very much alive. She is ready once again to take up her calling as the official thorn in the side of the financial services industry, and to vindicate herself in a court of law.

In Requiem

So it is fitting at this time that this coroner’s report becomes a eulogy we should bow our heads and observe a moment of silence. Thus do we pay our respects to the ideals, which Marcia’s career stood for, the integrity of the financial services industry and the preservation of the public trust in relation thereto? It is fitting that we say a prayer as well, in memory of what should have been a thriving career, cut short in the bloom of its youth.
We should say a more fervent prayer, a lamentation, in fact, for the financial services industry as a whole. Truly its institutions are sick unto death; truly, it is dying of cancer. Already the disease has spread and has all but consumed the integrity of the regulatory agencies mandated to hold the cancer in check.

But above all, pray for the individual investor, that God may guide him though the valley of the shadow of corruption and into the arms of another honest broker like Marcia.

Let not this death of a saleswoman be in vain.

Finis