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