FINRA’s Department of Enforcement investigated Dugan and found he falsely listed himself as the broker of record on applications and other firm documents for 23 variable annuity transactions. According to FINRA, Dugan listed himself as the broker of record on the applications despite knowing another broker at the firm actually recommended the annuities. During the relevant time period, Sandlapper’s procedures prohibited firm employees from falsifying firm documents, including but not limited to, listing oneself as the broker of record for transactions where another broker recommended the transaction(s).
Dugan’s alleged misconduct violated multiple FINRA Rules, including FINRA Rules 2010 and 4511. FINRA Rule 2010 requires members to comply with “high standards of commercial honor and just and equitable principles of trade.” Here, Dugan falsely listed himself as the broker of record on the variable annuity paperwork in direct contravention to Sandlapper’s procedures and in violation of financial industry rules and regulations.
Lufrano Law, LLC is a national securities litigation firm and has experience representing investors who have investment disputes with brokers and broker-dealers. If you suffered losses as a result of investing in variable annuities sold by Dugan through Sandlapper, or if you believe that you have been a victim of securities and investment fraud including falsified documents, please complete our contact form below or contact one of our attorneys at (800) 627-2179.