A broker in Annapolis, MD, agreed to be barred from the industry to settle FINRA charges she made unsuitable recommendations to her elderly clients to purchase variable annuities.  The RR, Cynthia Bulinski, is alleged to have repeatedly failed to tailor her recommendations to meet her customers’ individual investment needs - and, instead chose to recommend the same variable annuity to her customers, irrespective of age, investment experience, liquidity needs, financial situation and risk tolerance.

    Enhanced Death Benefits.   Not only did the RR have the temerity to recommend the same product to her elderly customers, but she also recommended that these customers tack on an enhanced death benefit rider - which, according to FINRA, could not be reasonably justified because some of the customers were too old to purchase the rider and the rest gained little, if any, benefit from the rider while paying a substantial cost for it. 

Additional alleged violations:

• RR recommended unsuitable variable annuities with a rider that was inconsistent with her customers’ investment objectives. 
• In numerous instances, RR demonstrated that she didn't understand the VA - describing the VA to one customer as a fixed annuity rather than a variable annuity;  with others, she incorrectly stated the surrender period and surrender charges her customers would incur.
• Several written customer complaints were received re: her lack of disclosure about surrender charges and other product details.

    Specific Numbers - Per the CRD.   In her detailed CRD report, Ms. Bulinski notes that FINRA investigated VA sales made between January 2004 and June 2005, when she says she was employed with McDonald Investments and worked out of Key Bank branch locations. 

FINRA notes that these VA sales in question were made while the RR was with 2 firms.  At her first firm, she was one of the Top 15 variable annuity producers and sold more VA's than any other RR at the firm.  At the 2nd firm, her compensation was derived exclusively from VA sales.  

In terms of numbers, FINRA points out that the same VA with an enhanced death benefit rider was recommended to 33 elderly customers in 48 transactions.  Unsuitable VA's with a rider that was inconsistent with the customers' investment objectives were recommended to 72 customers in 92 transactions.

    [C-I Question.  Where the bleep were the sales supervisers at these broker-dealers? ]

This is FINRA Case #2005002244704.   [Disciplinary Actions for February]