2009018295601
Hulke engaged in outside business activities through his association with an insurance company, but failed to notify his firm of this relationship or submit the required outside business activity disclosure form. The firm uncovered Hulke’s association with the insurance company when it investigated Hulke’s reversal of a customer’s purchase of a fixed annuity entered through the firm. The firm discovered that Hulke had executed the same fixed annuity transaction for the same customer through the insurance company. Hulke received a commission for the purchase of the fixed annuity executed through the insurance company; the firm also discovered several other instances where Hulke sold annuity and life insurance policies to customers that resulted in additional commission payments to him outside of his firm.
Hulke failed to respond to FINRA requests for information and on-the-record testimony.