CLAIMANT ALLEGES NEGLIGENT MISREPPRESENTATION IN PRODUCING FALSE ACCOUNT STATEMENTS; FRAUD, INTENTIONAL MISREPRESENTATIONS AND/OR OMISSIONS BY STATING INVALID POSITIONS AND VALUE; AND BREACH OF FIDUCIARY DUTY WITH UNSUITABLE INVESTMENTS, EXCESSIVE TRADING, UNAUTHORIZED WITHDRAWALS AND SURRENDERS, SIGNATURE FORGERIES AND EXCESSIVE FEES AND COMMISSIONS. CLAIMANT ALSO ALLEGES UNSUITABLE TRANSACTIONS, UNAUTHORIZED TRANSACTIONS, CHURNING, ELDER ABUSE, EMOTIONAL DISTRESS AND BREACH OF CONTRACT.

$1,000,000.00

$2,365,885.00

FINRA

SEC SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934, AND RULE 10B-5 PROMULGATED THEREUNDER, NASD RULES 2110, 2120, 2310, 2510(B), 8210, INTERPRETATIVE MATERIAL-2310-2: SALEH MADE RECOMMENDATIONS TO CUSTOMERS WITHOUT HAVING REASONABLE GROUNDS FOR BELIEVING THAT THE RECOMMENDATIONS AND RESULTANT TRANSACTIONS WERE SUITABLE FOR THE CUSTOMERS ON THE BASIC OF INFORMATION KNOWN TO HER ABOUT THEIR OTHER SECURITY HOLDINGS AND THEIR FINANCIAL SITUATIONS AND NEEDS, INCLUDING BUT NOT LIMITED TO UNDUE CONCENTRATION AND RISK OF LOSS OF PRINCIPAL. SALEH RECOMMENDED AND CAUSED CUSTOMERS TO LIQUIDATE VARIABLE ANNUITIES IN WHOLE OR IN PART AND TO PURCHASE OTHER VARIABLE ANNUITIES AND MADE THE RECOMMENDATIONS WITHOUT HAVING REASONABLE GROUNDS FOR BELIEVING THEM TO BE SUITABLE CAUSING THE CUSTOMERS TO INCURRED SURRENDER CHARGES AND DECREASED LIQUIDITY, BUT RECEIVED NO MEANINGFUL INVESTMENT BENEFIT. SALEH, WITHOUT THE KNOWLEDGE, AUTHORIZATION OR CONSENT OF CUSTOMERS, PLACED OR CAUSED TO BE PLACED FALSE CUSTOMER SIGNATURES ON VARIABLE ANNUITIES DOCUMENTS REQUIRING SIGNATURE. SALEH PLACED OR CAUSED TO BE PLACED FALSE AND INACCURATE INFORMATION ON DOCUMENTS RELATED TO ANNUITY TRANSACTIONS AND OMITTED TO DISCLOSE THAT THE TRANSACTIONS WERE ANNUITY EXCHANGES AND SUBMITTED THE FORMS TO HER EMPLOYER MEMBER FIRM AND TO INSURANCE COMPANIES FOR TRANSACTIONS. SALEH PROVIDED OR CAUSED TO BE PROVIDED FALSE PORTFOLIO STATEMENTS AND INSURANCE ACCOUNT HISTORIES THAT REFLECTED FALSE AND INACCURATE INFORMATION REGARDING INVESTMENTS IN VARIABLE ANNUITIES. SALEH PROVIDED OR CAUSED TO BE PROVIDED TO CUSTOMERS FALSE PORTFOLIO STATEMENTS. SALEH FAILED TO DISCLOSE TO EACH OF THE CUSTOMERS OR TO THE FIRM WITH WHICH SHE WAS ASSOCIATED THAT CERTAIN ANNUITY TRANSACTIONS CONSTITUTED AN EXCHANGE OR SWITCH BETWEEN INSURANCE PRODUCTS. SALEH CAUSED THE BOOKS AND RECORDS OF THE FIRM WITH WHICH SHE WAS ASSOCIATED TO REFLECT INACCURATE INFORMATION REGARDING THE CUSTOMERS' INVESTMENTS IN VARIABLE ANNUITIES. SALEH EFFECTED PURCHASES AND SALES IN THE ACCOUNTS OF CUSTOMERS WITHOUT THE CUSTOMERS' KNOWLEDGE, AUTHORIZATION OR CONSENT AND EFFECTED THESE PURCHASES AND SALES WITHOUT RECEIVING PRIOR WRITTEN AUTHORIZATION FROM THE CUSTOMERS TO EXERCISE DISCRETION AND WITHOUT THE FIRM'S WRITTEN ACCEPTANCE OF THE ACCOUNTS AS DISCRETIONARY. SALEH FALSELY REPRESENTED THAT SHE WAS A CUSTOMER IN TELEPHONE CONVERSATION WITH INSURANCE COMPANY. SALEH, BY ENGAGING IN SOME OF THE CONDUCTS, DIRECTLY OR INDIRECTLY, IN CONNECTION WITH THE PURCHASE OR SALE OF SECURITIES, BY USE OF MEANS OF INSTRUMENTALITIES OF INTERSTATE COMMERCE, OR OF THE MAILS, OR OF THE FACILITIES OF A NATIONAL SECURITIES EXCHANGE, WITH SCIENTER: EMPLOYED DEVICES, SCHEMES OR ARTIFICES TO DEFRAUD; MADE UNTRUE STATEMENTS OF MATERIAL FACT OR OMITTED TO STATE A MATERIAL FACT NECESSARY IN ORDER TO MAKE THE STATEMENTS MADE, IN THE LIGHT OF THE CIRCUMSTANCES UNDER WHICH THEY WERE MADE, NOT MISLEADING; OR ENGAGED IN ACTS, PRACTICES OR COURSES OF BUSINESS WHICH OPERATED OR WOULD OPERATE AS FRAUD OR DECEIT UPON ANY PERSON. SALEH MADE FALSE AND MISLEADING STATEMENTS DURING APPEARANCES WITH FINRA FOR ON-THE-RECORD ("OTR") TESTIMONY.

Decision & Order of Offer of Settlement

Bar (Permanent)

All Capacities

8/5/2009

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