On March 1, 2020, a client emailed the Organization to advise that his mail was being delivered to his old address and to provide the Organization with his updated address. An employee matched the client name to another client in the Organization?s database who had an identical first and last name and similar address. The employee did not validate additional information to ensure the correct client information was updated. Between March 1, 2020 and July 6, 2020, statements intended for the client were sent to an unintended recipient. Because the unintended recipient thought the statements concerned his own account, he made a transfer request, and assets were transferred out of the account in August. On December 15, 2020, the client contacted their Advisor about the status of their investments and it was found that the assets had left the Organization.
P2021-ND-214
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