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.

Jeffrey David Rosen (Principal)
AWC/2009021029611

Because certain states began requiring individuals to successfully complete a LTC CE course before selling long-term care insurance products to retail customers, Rosen created an answer key for a long-term care exam for one state and also instructed some of his direct reports to create answer keys for exams. Rosen distributed answer keys to the exams to firm employees and instructed his direct reports to obtain from and provide answer keys to other firm employees; the direct reports provided the answers to financial advisors at other firms and Rosen was aware that they had done so. Rosen failed to supervise his direct reports, in that certain registered individuals who reported to him created answer keys to LTC CE exams, obtained from, and provided answer keys to, other employees, provided the answers to financial advisors and Rosen was aware that they had done so.

Jeffrey David Rosen (Principal): Fined $10,000; Suspended 3 months in all capacities; Suspended 6 months in Principal capacity only

Tags: Testing  CE