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Regulatory Sanctions

Insurance Broker Paid Commissions on 28 Fictitious Policies – Then Gets U5’d

July 10, 2017

by Howard Haykin


Christopher Solomon agreed to be barred from the industry to settle FINRA charges that he submitted to his member firm’s insurance affiliate fictitious non-variable life insurance applications on behalf of purported customers.


BACKGROUND.    Christopher Solomon, a resident of Brentwood, MO, entered the securities industry in May 2012 when he became associated with Northwestern Mutual Investment Services. Solomon sold traditional insurance products through Northwestern Mutual's insurance affiliate, Northwestern Mutual Life Insurance Company. While Solomon tried but failed to pass the Series 6 (Investment Company Products and Variable Contracts Rep) licensing exam, he nevertheless was an associated person of a FINRA member firm.


FINRA FINDINGS.    Solomon may not have been smart enough to pass the Series 6 licensing exam, but from November 2015 to April 2016 he managed to hoodwink his firm’s insurance affiliate into issuing insurance policies on non-existent customers. Solomon submitted at least 28 fictitious non-variable life insurance applications to his Firm's insurance affiliate for fictitious customers. Solomon fabricated customer information on the insurance applications and created fake addresses, bank account numbers, social security numbers and driver’s license numbers. Solomon also signed the applications with the names of the fictitious customers.


FINRA notes that “Solomon wrote these applications in an effort to maintain his leadership position at the Firm.” [although it’s unclear what FINRA meant by “leadership position.”]


The firm’s insurance affiliate accepted 11 of the 28 submitted insurance applications and issued policies to fictitious individuals. Solomon even earned about $25,000 in commissions from the issuance of these false policies. When the premium payments on the issued policies were rejected due to false bank account information, Solomon simply accessed the firm’s online system and updated the bank information with new false bank account numbers. That extended the status of the issued policies – at least for a time.


Just imagine how interesting things would have gotten if Solomon tried to file a death benefit claim on the issued policies.


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

For details on this case, go to ...  FINRA Disciplinary Actions Online, and refer to Case #2016050443501.