Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
CONTINUING EDUCATION
2011
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.
September 2011 - View all for this month
Scott Roy Pierson
AWC/2009020572801

Pierson administered an insurance company’s insurance CE instruction program for his member firm, and because of a heavy workload, he got behind in the administration of the program, resulting in expired courses being taught and the late filing of courses, instructor approval requests and attendance rosters with states. To cover up these problems, Pierson issued false CE completion certificates to course attendees and substituted on CE completion certificates the names of state-certified instructors for courses uncertified instructors taught.

CE courses require annual or biannual renewals in some states, and Pierson allowed courses to expire without renewal.  Pierson wasn’t aware the courses had expired until after they had been taught. On one occasion Pierson issued certificates of completion for approved courses as opposed to the expired courses that were actually presented and did this over approximately a five-year period.

On one occasion Pierson issued CE completion certificates to course attendees for one hour of credit that had not been taught. In addition, Pierson substituted the names of state-certified instructors on CE completion certificates to conceal the fact that the instructors who actually taught the courses were not certified at the time the courses were taught.

Scott Roy Pierson : Fined $15,000; Suspended 1 year; Required to requalify as an investment company/variable contract products representative.
Bill Singer's Comment

Yeah, okay -- got it. I'm not defending Pierson and understand why FINRA was so upset. On the other hand, the whole CE crap and the cottage industry that it has prompted is also upsetting.  Ask virtually any individual who is required by any profession to take CE credits and you're likely going to hear the same complaints: it's too time consuming, it's too expensive, and the courses suck.  While the goal of CE is admirable, the reality is that little, if any, continuing education results from the forced attendance. 

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