by Howard Haykin

Both Scott Brandle and Nasrollah Hatami agreed to pay a $7.5K fine and serve a 3-month suspension to settle their same respective FINRA charges - that each caused his member firm’s books and records to be inaccurate by signing his name as the broker of record on variable annuity applications for customers, even though he did not substantially participate in the sales of the annuities to these customers.

BACKGROUNDS.   Both brokers worked for Allstate Financial Services at the time of their alleged violative activities.

• Scott Brandle, who resides in Brick, NJ, had been in the securities industry for 28 years – the last 11 years registered with Allstate in its Shrewsbury, NJ, branch office. He held the following registrations: (i) General Securities Rep, (ii) Investment Company Products/Variable Contracts Rep, (iii) Investment Company Products/Variable Contracts Principal; and, (iv) Municipal Fund Securities Principal. Brandle was U5’d by Allstate as of 1/6/17, and is not currently associated with a FINRA member firm.

• Nasrollah Hatami, who resides in Island Heights, NJ, entered the securities industry in November 2001 and he worked for Allstate in its Toms River, NJ, branch office for 13 years – from March 2003 to December 2016. He was registered as an Investment Company and Variable Contracts Products Rep. Hatami was U5’d by Allstate as of 11/22/16, and he is not currently associated with a FINRA member firm.

FINRA FINDINGS - SCOTT BRANDLE.    Between February and March 2016, Brandle signed his name as the soliciting registered rep on 4 variable annuity applications for 4 separate customers, even though he had never met these customers and he had not substantially participated in the sales of the annuities to these customers. The business was actually solicited by (LW), who was formerly registered with Allstate FInancial Services. Brandle received $1,107.81 in commissions from the sale of the annuities and shared these commissions with LW.

FINRA FINDINGS - NASROLLAH HATAMI.    Hatami's circumstances nearly identical to those of Scott Brandle - only the dates and transactional detail differ. In December 2015, Hatami signed his name as the soliciting registered rep on 3 variable annuity applications for 3 separate customers. Hatami received $3,340.91 in commissions from the sale of the annuities and shared these commissions with LW. In addition, between December 2015 and March 2016, Hatami earned an additional $5,671.15 in commissions from the sales of 4 other variable annuity policies to 3 other customers. Hatami also shared all $9,012 in commissions with LW.

VIOLATIONS OF FINRA RULES.    By each signing his name as the broker of record on the V/A applications, and then by sharing securities commissions with an unregistered individual, both Brandle and Hatami violated: (i) FINRA Rule 2040 (Payments to Unregistered Persons);  (ii) FINRA Rule 4511 ( Books and Records);  and, (iii) FINRA Rule 2010 (Standards of Commercial Honor and Principles of Trade).

This case was reported in FINRA Disciplinary Actions for June 2017.

For details on the Brandle case, go to ...  FINRA Disciplinary Actions Online, and refer to Case #2016050435301.

For details on the Hatami case, go to ...  FINRA Disciplinary Actions Online, and refer to Case #2016050441001.