NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

Jeff Yuejian Pan (Principal)
AWC/2007010636701

Pan completed and submitted to his member firm variable universal life insurance applications for public customers on which he falsified the customers’ states of residence in order to circumvent state registration requirements because Pan was not registered in the states in which the customers resided. Also, Pan provided false financial information on an insurance application in connection with the purchase of a life insurance policy by a corporation he owned in order to obtain approval of the policy. 

Jeff Yuejian Pan (Principal): Fined $5,000; Suspended 18 months in all capacities