NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

Steven Effron
AWC/2007009353701

While Effron was registered with a member firm, he engaged in outside business activities and failed to provide prompt written notice by completing and submitting an Outside Business Activity Notification Form. 

Effron placed variable annuity transactions through his member firm for customers of a representative from another member firm without discussing the transactions with the customers, and after receiving the completed and signed applications, he submitted them to his firm for processing. Effron received commissions from the transactions and forwarded most of the commissions to the representative without advising his firm of the arrangement. 

Steven Effron: Fined $10,000; Suspended 4 months in all capacities