Enforcement Actions
Financial Industry Regulatory Authority (FINRA)
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.
June 2011
Matthew Mark Rairigh
AWC/2009018240001/June 2011
Rairigh submitted false life insurance applications to an insurance carrier in order to generate commissions and to inflate his production numbers. The proposed insureds had never agreed to apply for the policies and the policies were submitted without their knowledge or consent. The Rairigh completed the life insurance applications, falsified the customersí signatures, listed his business address as the address to send the next quarterly premium notice and paid the initial premium. After the life insurance policy was issued, Rairigh would take the policy to the customer and seek to convince the customer to keep the policy by explaining that the customer merely had to continue to pay the quarterly premiums in order to keep it.
Matthew Mark Rairigh : Barred
Tags:  Production Quota     |    In: Cases of Note : FINRA
Bill Singer's Comment

Talk about putting the carriage before the horse.  First you submit the policy for production credit and then you try to actually sell it to the client.  Okay, Fire, Aim, and Ready!

You think this is a rare case?  Read HERE: http://www.rrbdlaw.com/enforcement-actions/tags.php?term=Production

March 2011
Dustin Kent Jefferies (Principal)
AWC/2009018919701/March 2011

Jefferies signed or traced customersí signatures on applications to purchase life insurance or critical care insurance through an electronic application system available at his member firm, without the customersí knowledge or consent and contrary to firm policy. Jefferies submitted life insurance applications for fictitious customers and, along with creating fictitious customer names and addresses, he created fictitious social security numbers, driverís license numbers and other information about the purported customers. Jefferies submitted these applications for fictitious customers in order to give the appearance that he was meeting his required production for insurance policies sold. When Jefferies submitted each of the fictitious applications, he listed fictitious credit card numbers made up of all zeros for the initial premium payment, knowing that the credit card would be rejected with no payment being collected or the customers billed, while at the same time, his firm would give him immediate credit for submitting a new insurance policy.

When questioned by his manager about the applications, Jefferies initially denied having any knowledge of the practice and when later pressured by his manager, he then offered that newer agents may have been engaged in the activity. Only after his manager noted that almost all of the applications with zeros for credit card numbers were submitted from his office that Jefferies admitted to his misconduct, stating he did so because the applications would be credited to his production numbers more promptly that month. In addition, Jefferies also admitted that he had submitted applications using fictitious names and other information.

Dustin Kent Jefferies (Principal): Fined $10,000; Barred in Principal capacity only; Suspended 1 year in all capacities
Tags:  Signature    Life Insurance    Production Quota     |    In: Cases of Note : FINRA
Bill Singer's Comment
Seriously? Really? OMG, what was he thinking??
February 2011
Randall Edgar Robinson II
AWC/2010022635301/February 2011
While serving as a licensed insurance agent, Robinson created fictitious property and casualty insurance policies in order to meet production goals with his firmís affiliated insurance company. Robinson did so by forging customer signatures or otherwise falsifying insurance application forms and related documents. Thefirmís affiliated insurance company paid Robinson approximately $16,000 in commissions as a result of the fictitious policies.
Randall Edgar Robinson II : Barred
Tags:  Production Quota    Forgery     |    In: Cases of Note : FINRA
Enforcement Actions