FINRA

NASD RULES 2110, 2310, 2821: BULINSKI, OVER THE COURSE OF MORE THAN FOUR YEARS, AND THROUGH HER EMPLOYMENT WITH TWO MEMBER FIRMS, MADE UNSUITABLE RECOMMENDATIONS TO HER ELDERLY CLIENTS TO PURCHASE VARIABLE ANNUITIES. SOME OF HER CUSTOMERS WERE OF MODEST MEANS AND SOME INVESTED MOST, IF NOT ALL, OF THEIR INVESTIBLE ASSETS IN THE VARIABLE ANNUITIES RECOMMENDED BY BULINSKI. BULINSKI REPEATEDLY FAILED TO TAILOR HER RECOMMENDATIONS TO MEET THE INDIVIDUAL INVESTMENT NEEDS OF HER CUSTOMERS, AND INSTEAD RECOMMENDED THE SAME VARIABLE ANNUITY TO HER CUSTOMERS, IRRESPECTIVE OF AGE, INVESTMENT EXPERIENCE, LIQUIDITY NEEDS, FINANCIAL SITUATION, AND RISK TOLERANCE. SHE RECOMMENDED TO 33 ELDERLY CUSTOMERS IN 48 TRANSACTIONS THAT EACH CUSTOMER PURCHASE THE SAME VARIABLE ANNUITY WITH AN ENHANCED DEATH BENEFIT RIDER, BUT DEMONSTRATED THAT SHE DID NOT HAVE REASONABLE BASIS FOR HER RECOMMENDATION BECAUSE NINE OF THE 33 CUSTOMERS WERE TOO OLD TO PURCHASE THE RIDER AND THE REST GAINED LITTLE, IF ANY BENEFIT, FROM THE RIDER WHILE PAYING A SUBSTANTIAL COST FOR IT. BULINSKI ALSO RECOMMENDED UNSUITABLE VARIABLE ANNUITIES WITH A RIDER THAT WAS INCONSISTENT WITH HER CUSTOMERS' INVESTMENT OBJECTIVES TO 72 CUSTOMERS IN 92 TRANSACTIONS. IN NUMEROUS INSTANCES, BULINSKI DEMONSTRATED THAT SHE DID NOT UNDERSTAND THE VARIABLE ANNUITY. SHE INACCURATELY DESCRIBED THE INVESTMENT TO A CUSTOMER AS A FIXED ANNUITY RATHER THAN A VARIABLE ANNUITY, AND WITH OTHER CUSTOMERS, INCORRECTLY STATED THE SURRENDER PERIOD AND SURRENDER CHARGES HER CUSTOMERS WOULD INCUR. AT HER FIRST FIRM, SHE WAS ONE OF THE TOP 15 VARIABLE ANNUITY PRODUCERS AND SOLD MORE VARIABLE ANNUITIES THAN ANY OTHER REGISTERED REPRESENTATIVE AT THE FIRM AND AT THE SECOND FIRM, HER COMPENSATION DERIVED EXCLUSIVELY FROM THE SALES OF VARIABLE ANNUITIES.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

12/17/2010

WITHOUT ADMITTING OR DENYING THE FINDINGS, BULINSKI CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE SHE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.

CLAIM WAS FOR U.S. AND N.Y.S. INCOME TAXES DUE TO ON THE SURRENDER OF AN IRA ANNUITY COMPLAINT WAS IN THE AMOUNT OF $25,098.00. RECEIVED LETTER FROM CLIENT'S ATTORNEY ALLEGING SHE WAS NOT INFORMED OF THE TAX IMPLICATIONS OF SURRENDING AN IRA VARIABLE ANNUITY.

$25,098.00

$5,100.00

CLAIMANT, [CUSTOMER], WAS AWARDED $5,000.00 ALL OTHER CLAIMS WERE DENIED. CLAIMANT, [CUSTOMER], PURCHASED A PREFERRED LIFE INS. CO. VARIABLE ANNUITY IN 1990 WITH THE TRANSFER OF HER DECEASED HUSBANDS, IRA. DUE TO AN EXTREME NEED FOR FUNDS, SHE SURRENDERED HER ACCOUNT IN 1995. THIS WAS HER ONLY OPTION, AS SHE HAD NO OTHER SOURCE OF FUNDS. SUBSEQUENTLY, SHE INCURRED A TAXABLE EVENT. HER CLAIM WAS THAT SHE WAS NOT TOLD OF THIS FACT. I, THE RESPONDENT, REPLY THAT SHE WAS TOLD AND DEFINITELY AWARE OF THE FACT THE SURRENDER OF HER IRA WOULD RESULT IN TAX CONSEQUENCES AND RECOMMENDED SHE SEE HER TAX ADVISOR BEFORE SURRENDERING.