Maybe it's me -- or maybe it's FINRA not fully explaining this case (or over-stating it to give a far worse appearance than it is). You tell me? A Principal invests an elderly client in worthless preferred stock using the proceeds of a VA that the Principal had earlier sold the elderly client -- and then the Principal lies about having been involved in any Private Securities Transactions.
Okay, so here's what's troubling me. FINRA doesn't tell us whether the Principal knew that the elderly client used the VA proceeds to fund the Pfd stock. We also don't know if the Principal solicited the borrowing from the VA, or was even aware of the source of the funds used to buy the Pfd. shares. Frankly, those strike me as important factors. Of course, there is that very ominous fact that Kahn lied on the certification -- was that intentional or unintentional? Again, FINRA ain't making that clear.
What I'm trying to understand is why a Principal who engaged in a VA-proceeds transaction that ultimately put an elderly client in worthless Pfd. shares and that same Principal then lies about his PST activity -- why that Principal is only suspended 6 months. Seems to me, if we make the likely inferences, he should be barred. However, as with many of these cases, the actual facts may be far more benign; hence, supporting the imposition of the fine and six-months suspension. Problem is -- we don't know from the official, published, monthly disciplinary squib. Hide-and-seek? Is this proper regulation?