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.

Kevin Lawrence Cohen (Principal), Dennis Stanley Kaminski (Principal), Gari Craig Sanfilippo (Principal)
EAF0400630001

Kaminski failed to supervise his member firm’s timely review of variable annuity transactions and failed to address the breakdown of the compliance department’s Trade Review Team’s review of Red Flag Blotters. Cohen and Sanfilippo created and maintained inaccurate books and records relating to the firm’s variable annuity trading. Cohen’s and Sanfilippo’s suspensions are in effect from October 18, 2010, through April 19, 2012. Kaminski has appealed to the SEC, and the sanctions are not in effect pending consideration of the appeal.

Sanctions imposed on appeal by the National Adjudicatory Council (NAC) following appeal and call for review of an Office of Hearing Officers (OHO) decision.

Kevin Lawrence Cohen: Suspended 18 months and required to requalify before acting in any capacity requiring qualification

Dennis Stanley Kaminski: Fined $50,000; Suspended 18 months and required to requalify before acting in any capacity requiring qualificationcapacity

Gari Craig Sanfilippo: Suspended 18 months and required to requalify before acting in any capacity requiring qualification

Tags: NAC