FINRA reported on at least 6 disciplinary actions against individuals who participated in, or sold, Universal Lease Programs (ULPs) - private placements.  Here are their stories.

For complete reads, click onto:   [FINRA Disciplinary Actions for December]

    1.  RR Flaherty (Alton, IL) agreed to a $21K fine and 4-month suspension, to settle FINRA charges he participated in the sales of ULPs, totaling $140,000 and generating $16K in commissions - which were paid to an entity established for his annuities and insurance business.  Flaherty failed to provide his firm with prior written notice about the sales and never got its written approval.    [C-I Note:  It's unlikely, though possible, that he disclosed the entity to his firm?]   (FINRA Case #2009016709016)

    2.  RR Gissendaner (Covington, GA), agreed to a $20.5K fine/disgorgement and 5-month suspension, to settle FINRA charges he engaged in private securities transactions when he sold ULPs in various resort properties to investors - totaling $173,000 and generating $15K in commissions.  Gissendaner failed to provide his firm with prior written notice and failed to get it's written approval.  He also lied on his firm’s Outside Business Activities/Private Securities Transactions form and Annual Compliance Questionnaire.     [C-I Note:  At least the firm "covered it back" by asking all the right questions on its affidavits.  Usually, it's all a firm can do - except in circumstances where it should have known that the transactions were being effected.]   (FINRA Case #2009016709013)

    3.  RR Kersey (Lawrenceville, GA) agreed to a $24.5K fine/disgorgement and 3-month suspension, to settle FINRA charges he engaged in private securities transactions when he sold securities in the form of ULPs in various resort properties to investors - generating $194K in sales, $19K in commissions.  No prior notice or firm approval.  (FINRA Case #2009016709012)

    4.  RR Moss (Los Angeles, CA) agreed to an $11K fine/disgorgement and 5-month suspension, to settle FINRA charges he participated in sale of ULPs - generating sales of $50K and commissions of $6K.  He also sold payphone programs, totaling $65,000, to members of the public, and he sold an automatic teller machine (ATM) program, totaling $48,000 plus $2,400 for surety bonds to members of the public.  In all 3 sales ventures:  No prior notice, no firm approval.  He also lied on firm's business activity statements, in which he agreed that he was aware that his firm must be notified of all his business activities, even those that did not relate to the securities industry.     [C-I Note:  That last element of the affidavit is quite effective because, while it may appear obvious, there's probably some good in stating the obvious - at least in this situation.  In some cases, we're dealing with "dolts," as that term only pertains to a particular RR's knowledge, interest or perception of compliance.]   (FINRA Case #2009016709015)

    5.  RR Oldham (Kenosha, WI) agreed to a 5-month suspension (could't afford a fine), to settle FINRA charges he sold ULPs - totaling $403K in sales, $18K in commissions.  No prior notice, no firm approval.   (FINRA Case #2009016709017)

    6.  RR Yingling (Colorado Springs, CO), agreed to a $7.5K fine/disgorgement and 15-day suspension, to settle FINRA charges he sold ULPs - totaling $45K in sales, $2K in commissions.  No prior notice, no firm approval.  (FINRA Case #2009016709014)