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.

Gregory Earl Hafen (Principal)
AWC/2009016709011

Hafen participated in the sales of Universal Lease Programs (ULPs) to members of the public totaling $482,015.64 and failed to provide his member firm with written notice and obtain the firm’s written approval. Hafen received approximately $42,960 in commissions from ULP sales.Hafen submitted an outside business activities questionnaire to his firm that failed to report that he was selling ULPs for compensation.

Gregory Earl Hafen (Principal): Fined $48,000 including disgorgement of commissions; Suspended 7 months

Tags: Universal Lease Programs