This Utah-based Registered Rep with Great American Advisors, agreed to settle FINRA charges he engaged in a pattern of unsuitable variable annuity switch transactions for numerous customers. FINRA Allegations of Findings. Jan David Henderson allegedly would switch customers from their existing fixed and/or variable annuities ("V/A") into a specific V/A, thereby improperly earning additional commissions at the expense of customers who paid substantial surrender fees.  For these switches, customers paid about $208,000 in surrender penalties and Henderson received over $380,000 in commissions.  It's not surprising to see on his CRD that, while he had just a single "regulatory event," Henderson had 12 customer disputes on file.

• Henderson executed the V/A replacement transactions without regard to the substantial surrender charges imposed or the extension of the surrender periods for his customers.  He did so utilizing a "one-size-fits-all" investment strategy for the customers, which was not suitable for his diverse client base.

• Henderson failed [C-I: Or chose not] to research and understand the salient features of the V/A, such as the other investment options and other riders available to his customers, only selecting and discussing with customers the same single investment option and the same single rider for all customers.  Truth be told, even before selling the V/A to any of his customers, he had already predetermined that he would sell his customers the same single investment option and the same single rider, based largely, if not exclusively, on representations a wholesaler made to him without conducting any of his own independent research or analysis.

• Henderson marketed the V/A to his customers based on the rider’s purported benefits.  However, he failed to correctly and accurately complete the V/A paperwork, which resulted in some of his customers not receiving the promised protection of a rider that he recommended at the time of the sale, thereby causing his member firm’s books and records to be inaccurate.

Imposed Sanction. Henderson was barred from the industry.  For further details, go to [FINRA AWC #2009019513901] and [Disciplinary Action for Sept 2011].