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.

Renee Lynn Coil
AWC/2008014756401/October 2010

Coil failed to

• determine the surrender fees related to variable annuity exchanges she recommended to a customer, and the customer agreed to the exchanges based on his understanding that there was no penalty associated with the exchanges; 
• perform adequate analysis on the variable annuities to determine their surrender periods and the customer was charged surrender fees totaling $26,286.84; and
• ensure that the imposition of the surrender fees was accurately disclosed on her member firm’s variable annuity switch form.

If the customer had held the variable annuities for two additional months, he would not have incurred the fees.

Renee Lynn Coil : No Fine in light of financial status; Suspended 1 month

Tags:  Surrender Charge    Variable Annuity     |    In: Cases of Note : FINRA

William Gregory Slonecker
2007009442501/September 2010

Slonecker recommended and executed unsuitable variable annuity contract replacements or switches involving customers without regard for their age or financial backgrounds, and received $85,000 in commissions. Slonecker’s customers received no significant benefit from the transactions but incurred substantial surrender charges, new extended surrender periods and, in some cases, paid additional fees.

Slonecker made numerous false entries in his member firm’s electronic order-entry system and on other firm records to obtain approval for the switches he recommended to the customers, causing his firm to create and maintain inaccurate books and records. Slonecker’s false entries in the firm’s electronic order-entry system and suitability questionnaires were material false representations he made to his firm.

Slonecker falsely represented to customers that surrender fees associated with the switches would be fully recovered by the bonuses they would receive from their purchases of new variable annuity contracts, when he knew or should have known that the bonuses did not offset the surrender fees and he failed to disclose and explain to the customers the surrender charges associated with switch transactions.

Slonecker failed to respond to FINRA requests for information.

William Gregory Slonecker: Barred

Tags:  Variable Annuity    Suitability    Surrender Charges     |    In: Cases of Note : FINRA