Ex-Advisor Solicited Client Money for Film Business, Regulators Say

A former Citigroup financial advisor faces proposed enforcement action by a federal banking regulator over allegations she solicited an older client to invest hundreds of thousands of dollars in her film production business.

The U.S. Office of the Comptroller of the Currency seeks to bar Helen G. Caldwell, formerly employed by Citibank and Citigroup Global Markets in Chicago, from participating in conducting the affairs of any federally insured bank, credit union or similar entity.

The action, announced in a filing this month, follows the Financial Industry Regulatory Authority’s move earlier this year to bar Caldwell, identified in a filing as Helen Grace Caldwell, for declining to testify in its investigation of her conduct.

Caldwell, a FINRA-registered broker with Citi from June 8, 2012, through Nov. 10, 2021, engaged in self-dealing at an elderly client’s expense — over $325,000 in checks written over two years — and concealed her activity from both Citibank and the affiliated brokerage, the OCC alleges.

During her near decade with Citi, Caldwell became 50% owner of Canal Productions, a film company, according to the OCC filing. Starting in late 2016, she became financial advisor to a Citibank and brokerage client, “Customer A,” an older woman living on her Social Security income who “may have been particularly vulnerable,” the OCC says.

Around Feb. 1, 2018, Caldwell “began soliciting Customer A to invest in Canal Productions” and didn’t reveal to Citi that she was doing so or “that Customer A, in fact, invested,” the regulator alleges.

That month, the customer wrote two checks from her Citibank account totaling $125,000 to Canal Productions, then wrote 10 checks totaling $200,500 to Canal from October 2018 to February 2020, the OCC filing says.

The checks were deposited into Canal’s Citibank account, which Caldwell controlled, and were used partly to pay Caldwell at least $99,000 from October 2018 to February 2020, it says. Citi policy prohibited Caldwell’s alleged activity with the customer, according to the OCC, which noted that she resigned from the company in November 2021.

The Internet Movie Database lists Helen Grace Caldwell as a producer, director and actress, including a credit as executive producer in a 2022 film called “Give Till It Hurts,” described as “a dark comedy set in the 80′s about two brothers seeking the return of their inheritance that their deceased mother donated to a televangelist.”

Three films listed in her IMDb credits appear to correspond to memos on Customer A’s checks listed in the OCC complaint.

The OCC alleges, among other points, that Caldwell “directly or indirectly engaged or participated in unsafe or unsound practices in connection with Citibank and/or the brokerage, and/or breached her fiduciary duty to Citibank,” and that Citi, due to this misconduct, has or will likely suffer financial loss or other damage.

An administrative law judge will hold a hearing on the matter at a date to be determined, according to a notice of charges that the OCC filed this month.

In July, FINRA announced that Caldwell accepted and consented to its findings without admitting or denying them, including that in 2022, Citigroup disclosed that an internal review “had concluded that Caldwell ‘did not adequately disclose her outside business activity, and was soliciting firm clients to invest in her outside business activity, several of whom subsequently made investments.’”

In addition, from Nov. 10, 2021, to September 2022, Caldwell was registered as a general securities representative through an association with Wells Fargo Clearing Services LLC, according to FINRA. On Sept. 15, 2022, Wells Fargo disclosed “that Caldwell had been discharged ‘following an internal review concerning the accuracy of disclosures’” that she made to the firm and her compliance with its outside activities and outside investment policy, FINRA says.

“Caldwell declined to provide on-the-record testimony,” in violation of FINRA rules, the organization says.

Caldwell didn’t immediately respond to a message Tuesday sent through her professional website. Her attorney on the FINRA filing didn’t immediately respond to an email seeking comment. A Citi representative didn’t immediately respond to an emailed request for comment.

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