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.
Hulke engaged in outside business activities through his association with an insurance company, but failed to notify his firm of this relationship or submit the required outside business activity disclosure form. The firm uncovered Hulkeís association with the insurance company when it investigated Hulkeís reversal of a customerís purchase of a fixed annuity entered through the firm. The firm discovered that Hulke had executed the same fixed annuity transaction for the same customer through the insurance company. Hulke received a commission for the purchase of the fixed annuity executed through the insurance company; the firm also discovered several other instances where Hulke sold annuity and life insurance policies to customers that resulted in additional commission payments to him outside of his firm.
Hulke failed to respond to FINRA requests for information and on-the-record testimony.
[In]Securities a Guest Blog byAegis J. Frumento, Partner, Stern Tannenbaum & BellMind Games Back in February I wrote about how GameStop was like a meme. http://www.brokeandbroker.com/5678/insecurities-aegis-frumento-gamestop/. Since then, the term "meme stocks" has caught on to describe those issuers whose market fortunes are propelled no... Read On