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ULP's: Bane of These Brokers' Existences
Universal Lease Programs commonly relate to "timeshares" of resort accommodations. For many of the 7 disciplined brokers, they resulted in a "ticket out of the industry." The programs often are coupled with pre-arranged service agreements with a leasing agent (who theoretically could rent the timeshares to others), and a guaranteed safe investment that paid the investor a high, fixed rate of return. The programs more often are shams - and Ponzi schemes - that paid selling brokers huge commissions.
Sales of these unregistered securities have been pursued by securities regulators for years - from the SEC to state securities commissions. So it's now time for FINRA to complete the loop in those cases involving persons registered with member firms. [For other cases, click onto: [ FINRA Disciplinary Actions for November ]
1. Reg'd Rep (S. Charleston, WV) fined, disgorged $7K, suspended 4 months. Allegedly participated in the sale of Universal Lease Programs (ULPs) without first notifying member firm in writing - nor disclosing on annual compliance questionnaire. RR earned all of $2,000 in commissions. (FINRA Case #2009016709009)2. Reg'd Principal (Cerritos, CA) fined, disgorged $9K, suspended 4 months. Same as #1, but earned $4,000 in commissions. (FINRA Case #2009016709008)
3. Reg'd Rep (Bolivia, NC) fined $15.5K, suspended 8 months. Same as #1. In addition, RR failed to timely respond to FINRA requests for information and documents. (FINRA Case #2009016709002)
4. Reg'd Rep (Evansvill, IN) fined, disgorged $20K, suspended 3 months. Same as #1, but earned $14,733 in commissions. (FINRA Case #2009016709005)
5. Reg'd Principal (Ontario, CA) barred from industry. Same as #1, but with these differences: this Principal had requested permission to sell ULP's outside of firm, but was denied. He made $30,270 in commissions. (FINRA Case #2009016709007)
6. Reg'd Rep (Evansville, IN) fined, disgorged $38.5K, suspended 1 year. Same as #1, although RR earned over $86,000 in commissions, and later repaid $52,500 to customers. (FINRA Case #2007009342201)
7. Reg'd Rep (Brookville, IN) fined, disgorged $15.5K, suspended 3 months. Same as #1, but earned $10,311 in commissions. (FINRA Case #2009016709006)

