The following information is from FINRA’s website under “Disciplinary and Other FINRA Actions, February, 2013.”

Delaney Equity Group, LLC (CRD #142285, Palm Beach Gardens, Florida) and David Cameron Delaney (CRD #2447186, Registered Principal, West Palm Beach, Florida)

were named respondents in a FINRA complaint alleging that the firm, acting through Delaney, its
president/CCO/AMLCO, failed to conduct adequate due diligence to determine whether they were participating in a scheme to evade the registration requirements of Section 5 of the Securities Act of 1933 by selling shares of low-priced equity securities that were unregistered and non-exempt.

The FINRA complaint alleges that a firm customer had obtained almost $2.4 million through the sale of these securities, which ceased only when the firm’s clearing firm restricted the customer’s accounts. The complaint alleges that the firm, acting through Delaney, relied on opinion letters by one counsel representing all of the issuers, who was later found to have issued inaccurate correspondence to the OTC markets and failed to note the contradiction in the customer’s actions and representations.

Delaney Equity Group, acting through Delaney, sold almost a billion shares of common stock on the customer’s behalf that were not registered with the SEC, and no exemption from registration applied to such sales.

FINRA’s complaint also alleges that the firm, acting through Delaney, failed to establish, maintain and enforce adequate policies and procedures, including WSPs, reasonably designed to ensure compliance with Section 5 of the Securities Act to prevent the sale of unregistered securities not exempt from registration. The firm, acting through Delaney, failed to develop and implement AML policies, procedures and internal controls reasonably designed to achieve compliance with the BSA and implementing regulations. The complaint further
alleges that the AML procedures failed to address the detection, monitoring, analyzing, investigating and reporting of suspicious activity in the context of its securities liquidation business. The firm, acting through Delaney, failed to enforce its WSPs and impose heightened supervision on the representative.

(FINRA Case #2010021108301)
This ends the information from FINRA’s website.

If you have suffered financial losses due to your broker/dealers’ recommendations, call Soreide Law Group for a free consultation with an attorney: 888-760-6552.

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The following information is from FINRA’s website under “Disciplinary and Other FINRA Actions, February, 2013.”

Richard Alan Seligson (CRD #3169733, Registered Representative, Boca Raton, Florida)

was fined $10,000, suspended from association with any FINRA member in any capacity for one year and
ordered to pay $41,100, plus interest, in restitution to customers. This fine and restitution must be paid either immediately upon Seligson’s reassociation with a FINRA member firm following his suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier.

Without admitting or denying the findings, Seligson consented to the described sanctions and to FINRA’s entry of findings that he borrowed $45,000 from close friends and relatives, all of whom were his firm’s customers.

FINRA’s findings stated that Seligson has repaid only $3,900 of the amount owed. Seligson did not seek to obtain his firm’s written approval to obtain loans from any of the customers. Seligson completed compliance questionnaires in which he was asked if he had entered into loans with customers. On each questionnaire, Seligson falsely answered that he had not taken such loans. The findings also stated that the firm’s WSPs generally prohibited representatives from taking loans from their customers, except under extremely rare and
extenuating circumstances. Under the firm’s procedures, these circumstances could include borrowing or lending arrangements with clients who were family members. The firm’s WSPs explicitly stated that requests to enter into borrowing or lending arrangements with family members had to be submitted for review and approval before engaging in lending activity.

The suspension is in effect from December 17, 2012, through December 16, 2013.
(FINRA Case #2011029460101)

The last two firms listed on FINRA’s BrokerCheck that Seligson was employed with are NATIONAL SECURITIES CORPORATION, BOCA RATON, FL from 10/2011 – 12/2011 and MORGAN STANLEY SMITH BARNEY, BOCA RATON, FL, from 06/2009 – 09/2011.

This ends the information from FINRA’s website.

If you find yourself in this or a similar situation with your broker or financial advisor, call Soreide Law Group for a free consultation with an attorney, 888-760-6552, or visit our website at: http://www.securitieslawyer.com.

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The Financial Industry Regulatory Authority, also known as FINRA, has been enforcing all types of annuity transaction misdeeds nationwide according to recent enforcement reports from the agency, writes Elizabeth Festa in a recent article for LifeHealthPro.com.

FINRA recently censured a firm and fined it $40,000 to settle allegations that the firm failed to maintain required documentation about variable annuity transactions and it’s customers. Sampled transactions of the firm, Allied Beacon Partners, Inc., Richmond, Va., lacked certain customer information or documentation needed in order to make a reasonable suitability determination.

“A large portion of variable annuity transactions sampled revealed the firm’s failure to ensure that a designated principal adequately reviewed and approved the customer’s application prior to its transmission to the issuing insurance company,” FINRA wrote.

FINRA reported that the firm’s Written Supervisory Procedures (WSPs) for variable annuity transactions were deficient. The WSPs identified one individual as having the responsibility to supervise variable transactions, but another individual not identified in the WSPs was actually the primary person responsible for supervising VA transactions, FINRA uncovered.

FINRA’s findings also said that the WSPs did not address how the firm would monitor compliance with SEC Rule 15c2-8, which requires that a prospectus be delivered to customers. The firm was unable to provide any documentation that a prospectus was sent to any of the customers, FINRA alleged.

FINRA also settled a matter involving a registered representative who recommended unsuitable transactions, a mortgage and a variable annuity, to a customer, a 53-year-old widow who worked as an administrative assistant for a public school system. Her annual salary was approximately $55,000, she owned a home unencumbered by a mortgage and valued at approximately $500,000, and she had an investment portfolio valued at approximately $160,000 in retirement accounts and $100,000 in certificates of deposit.

In another recent case, FINRA found that the representative did not have a reasonable basis for recommending that the customer mortgage her primary residence to invest $300,000 in a variable annuity, given that the customer intended to retire in seven years, had limited income, expected an equally limited retirement income and would have an insufficient monthly income to make the mortgage payments.

FINRA concluded that the registered representative’s conduct violated rules of ethical standards and rules concerning recommendations to customers. FINRA fined the representative $5,000 and suspended him in all capacities for 10 business days.

In another FINRA case, a registered representative in Naples, Fla.,was fined $25,000 and suspended from association with any FINRA member in any capacity for three month. He consented to findings that he recommended and executed a variable annuity replacement contract for a member firm customer in a state in which he was not licensed to sell insurance products and included false information in the firm’s electronic books and records.

FINRA’s findings stated that he logged into his member firm’s Web-based system utilized by firm sales staff to complete transaction paperwork for annuity contract purchases reporting that the customer was a New York state resident. When the system rejected the replacement transaction because the deferred VA product was not offered to New York residents and because he did not hold the requisite state insurance license, he listed the customer’s state of residence as Florida.

The National Association of Insurance Commissioners (NAIC) revised its annuity sales model regulation in March, 2010, to provide annuity protections for consumers of any age, (such as the 53 year-old widow), requiring insurer reviews of every annuity transaction, and clarifying that insurers are responsible for compliance with annuity protection provisions — even when insurers contract with third parties.

A Florida regulatory-supported bill died in the Florida Banking & Insurance Committee back in March, 2012. Florida, which has one of the highest senior population rates in the country, would have become the 20th state to enact the revised model law on annuities.

If you or a family member have become alleged victims of annuity or insurance fraud, contact an attorney at Soreide Law Group for a free consultation on how to recover your investment losses. To speak with an attorney, call 888-760-6552, or visit http://www.securitieslawyer.com.
Soreide Law Group, PLLC, representing Insurance Fraud Victims in Federal Court, State Court, and before the Financial Industry Regulatory Authority (“FINRA”).

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Christopher Andrew Carra (CRD #2214509, Registered Representative, Deerfield Beach,Florida)

was fined $20,000 and suspended from association with any FINRA member in any capacity for one year.

Without admitting or denying FINRA’s findings, Carra consented to the described sanctions and to the entry of findings that he attempted to procure investment banking and consulting business from a publicly traded company and posted comments on an Internet message board about the company under numerous author names.

According to FINRA’s findings, several statements in the postings were unwarranted and misleading; some involved conversations between his different handles in which he embellished the prospects for the company.

FINRA’s findings stated that to make the postings, Carra used multiple outside or non-firm-provided email addresses, in violation of his member firm’s WSPs. Carra also used two outside email addresses to communicate with company representatives about business-related matters, in violation of his firm’s WSPs.

FINRA found that one of the outside email addresses may have given the impression that it was a firmprovided email address when it was not one.

The suspension is in effect from July 16, 2012, through July 15, 2013.
(FINRA Case #2011030840501)

This information was listed on FINRA’s website under “Disciplinary and Other FINRA Actions, August, 2012.”

Soreide Law Group, PLLC, represents clients nationwide. Call for a free consultation on how to potentially recover your losses. To speak with an attorney call 888-760-6552, or visit our website at: http://www.securitieslawyer.com.

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