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.
Davidson requested and received answer keys for state insurance LTC CE exams for several states from member firm employees who created them and then distributed them to another firm employee and financial advisors outside the firm. Davidson asked his internal wholesaler to provide him with the last four digits of the wholesaler’s social security number so that he could take one state’s LTC CE online exam and use the information to satisfy the online requirement of having someone proctor the exam. Davidson used the partial social security number to log in and access the exam, but did not complete the exam, but, in so doing, misrepresented having a proctor for the exam.
Jonathan Ross Davidson : Fiend $5,000; Suspended 45 days