FINRA highlighted three cases in which associated persons lacked proper registrations, and where an RR lacked qualifications to sell annuities.  Their stories:

1. Unregistered Associated Person Acting in Capacity Requiring Registration.
2. Registered Person Engaging in Conduct for Which He Is Not Properly Licensed.
3. Participating in Sales of Equity-Indexed Annuities Without Having Been Appointed as a Selling Agent.

    1.  Unregistered Associated Person Acting in Capacity Requiring Registration.   An associated person ("AP") settled FINRA charges that, for one year, the individual acted as CCO for a member firm.  In this capacity, the AP was required to have a Series 7 or Series 62 (corp. securities limited rep) license, and a Series 24 principal's license.   For having allegedly violated NASD Rules 1021, 1031 and 2110, the AP was fined $10,000 and suspended 10 days in all capacities.

    2.  Registered Person Engaging in Conduct for Which He Is Not Properly Licensed.   An RR settled charges he engaged in conduct at his member firm for which he was not properly licensed - i.e., proprietary options trading for the firm for over a year.  The RR held a Series 62 (corp. securities limited rep) license, but also needed the Series 42 (registered options rep.) license.  Series 62 expressly prohibits prop options trading unless separately licensed to do so.  For having allegedly violated NASD Rules 2110 and 1031, the RR was fined $15,000.

    3.  Participating in Sales of Equity-Indexed Annuities Without Having Been Appointed as a Selling Agent.   An RR settled charged he had participated in sales of equity-indexed annuities without having been appointed as a selling agent and without firm approval of the sales.  He managed this through his informal partnership with another RR, whereby the two did financial planning for retiring city employees and sold equity-indexed annuities.  For nearly 2 years, the RR participated in the annuities sales - discussing their general features and benefits with customers, facilitating the transactions, introducing the customers to his partner to complete the transactions.  In all the pair "collaborated on sales to 15 customers issued by 3 companies for whom the representative was not an appointed agent.  With respect to these sales, the customers were unaware that the firm didn't have selling agreements with the issuers and did not approve of the sales. For having allegedly violated NASD Rules 2110 and 1031, the RR was fined $5,000 and suspended 10 days.    [ FINRA Quarterly Review, October ]