This Registered Rep with Lincoln Financial Distributors (Lincoln), was fined and suspended, then terminated for improperly administrating a Continuing Education program for an affiliated life insurance company. Administration of the CE Program. Lincoln National Life Insurance Company ("LNL")  owns and pays for a program that provides state insurance CE courses taught by employees of Lincoln or its affiliates to non-Lincoln financial advisors (the UCE Program").   Administration of the CE program included:  (i) filing CE courses with the states to get them approved, (ii) getting courses reapproved after they had expired, (iii) filing course completions - e.g. attendance rosters - with the states, (iv) filing advanced notifications of CE courses with states, (v) sending attendees completion certificates, (vi) filing instructor approval requests with states, (vii) assisting in the creation of a website for the CE Program, and, (viii) working with wholesalers and other experts to get material for the CE courses. Scott Roy Pierson was the "last man standing" in the CE Section after the department was significantly reorganized and downsized in December 2008 - this included terminating the CE Section Manager and another one of the CE Coordinators.  Pierson, a full-time employee, was assisted by 2 part-time administrative assistants. FINRA Allegations of Findings. From the get-go, in January or February 2009, Pierson ran into problems.  Heavy workload caused him to fall behind in his administration, which led him to commit the following alleged blunders:

• he allowed expired state insurance CE courses to be taught;
• he issued false CE completion certificates; and
• he substituted on CE completion certificates the names of state-certified instructors who had not presented CE courses for the names of the uncertified instructors who had presented CE courses.

To cover up these administrative problems, Pierson began issuing false CE completion certificates to course attendees - that started around September 2009.  He also substituted on CE completion certificates the names of state-certified instructors for courses that had been taught by uncertified instructors.  He also allowed some 29 expired courses to be taught - he was not aware that the courses had expired until after they had been taught.  Such conduct violated NASD Rule 2110 and FINRA Rule 2010.

[C-I Note: We wonder whether he would have been disciplined and terminated to the same extent if he owned up to management that he was overwhelmed and couldn't handle the workload.  C-I is not sure from FINRA documentation as to whether any of these violations occurred prior to the departmental reorganization.]

FINRA further noted that Pierson allegedly issued certificates of completion for approved courses as opposed to the expired courses that were actually presented.  The regulator also found that on one occasion Pierson issued CE completion certificates to course attendees for one hour of credit that had not been taught. FINRA Sanctions. Pierson was fined $15K, suspended for one year and required to requalify as an investment company/variable contract products representative.   He was terminated by his firm in 2010.   For further  details, go to:   (FINRA AWC #2009020572801).