The SEC said SARC took “limited” steps to investigate the matter. “Aside from the branch manager’s notes and meeting summaries which were provided to SARC, neither the SARC analyst nor anyone else from SARC ever spoke to the customers, branch manager, or Stow,” the SEC said.

“Upon completing this limited investigation, on July 10, 2018, the SARC analyst replied to compliance officer’s initial email, stating that he did not see anything that would require SARC to take immediate action, such as Adult Protective Services notification or account restrictions,” the SEC said. The SEC further noted that “when SARC’s work was completed, Stow’s supervisors were not adequately informed that the review of Stow’s customers focused on external threats.”

The SEC said Stow’s performance continued to decline after the SARC review and in November he was placed on a performance improvement plan. But the SEC said from July 2018 to March 2019, when the war veteran died, Stow continued to steal monthly from his account. 

When that account was frozen, Stow dipped into the account of the elderly woman. He  confessed his scheme to his supervisor in May 2019 after being questioned repeatedly by the executor of customer’s estate about the missing money, the SEC said.

Stow entered the industry in 1979 and worked for Merrill Lynch for 10 years before moving to several firms including Suntrust Equitable Securities and Wells Fargo Advisors before joining Raymond James in 2013, according to BrokerCheck.

He was fired by Raymond James in May 2019 and barred by the Financial Industry Regulatory Authority in October 2019 for not cooperating with its investigation of the case. The SEC barred him in July 2021.

The SEC said as a part of the settlement offer, Raymond James has taken remedial steps to improve its SARC program. Among other things, it said the firm has enhanced “SARC’s communication with supervisors and control functions and provides “boots on the ground” engagement by supervisory personnel on senior exploitation issues.”

Raymond James did not respond to an inquiry for a comment.

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