Without indicating the age of the clients in the monthly squib report (FINRA merely provides us with the conclusory "young" age characterization in the monthly report -- clearly, since the age is a critical component of this case, FINRA should have published the ages in the monthly abstract), the regulator charges that purchasing a $1 million life insurance policy was a violation because 1. the funding came from $30,000 to be used to make a down payment on a home; and 2. the customers were "too young" to own such a policy; and 3. they had a lack of need for a $1 million life insurance policy.

While all of the reasons for brining the charges may well prove correct, I don't buy the case solely based upon the fact pattern in the online monthly disciplinary report. 

• First off, did any one determine whether the customers were "too young" to be putting $30,000 into a home -- and what about the value of the purchased home, was that also "suitable" for this young couple? 
• How does one determine whether a young couple with at least $30,000 in assets has or does not have a need for a $1 million life insurance policy?
• Did FINRA determine that the couple had no need for any life insurance or a need for only up-to $500,000? 
• Assuming that one of the customers was the sole breadwinner for the family (that is merely conjecture for the sake of making a point), if he/she dies next week, would the other party (and are there any children?) be better off with a $1 million life insurance policy or ownership of a home with only $30,000 paid-in equity?

Again, there are probably significant facts that justify FINRA's position but the regulator needs to detail those in its monthly report if the case and its sanctions are to be meaningful as a regulatory tool to educate the industry and investing public.

UPDATE: I obtained a copy of the AWC and discovered the following additional facts not disclosed in the monthly squib report. At the time of the sale, the couple were 25 and 26 years of age and were not then married. As of April 2007, the intended house purchase was to be made in 2009 or 2010 with the $30,000 as a deposit.  Rogers recommended that the couple each purchsae a $1 million variable life insurance policy. Rogers total commissions on both purchases was $6,841.22. FINRA apparently concluded that given the couples' age that the recommendation was unsuitable because they had earmarked the $30,000 for a future house purchase and the variable life policies exposed them to market risk and did not provide the couple with "liquidity" for the invested sums. FINRA also noted that if the couple decided to cash out their policies to puchase a home in 2009/2010, that there would be a surrender charge.  Moreover, FINRA seems to have concluded that a young couple in their 20s "given their particular financial situation " (not explained by FINRA) "did not have a financial need to each have a$1,000,000 in insurance coverage. " The couple subsequently married in November 2007.