FINRA

Without admitting or denying the findings, Cumber consented to the sanctions and to the entry of findings that he conducted insurance sales through a limited liability company he formed and he did not disclose any of the insurance business, residual commissions, or the existence of the company to his member firm. The findings stated that Cumber falsely attested to the firm that he was not involved in any outside business activities and repeatedly acknowledged his understanding that the receipt of residual commissions should be disclosed to the firm through an outside business activity disclosure. On two occasions, Cumber also explicitly agreed that he would not sell insurance products for any entity other than the firm without prior notice and approval. The findings also stated that Cumber engaged in 24 equity-indexed annuity sales to 20 individuals (13 of whom were the firm's customers). The sales totaled approximately $2.63 million, and Cumber earned approximately $125,000 in commissions from the associated insurance company. Also, Cumber received approximately $27,000 in trailing compensation in connection with previous sales of insurance products. These payments were received by Cumber's entity, the company. While associated with the firm, Cumber received approximately $345,000 in payments from the insurance company for sales of equity-indexed annuities and other insurance products.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$7,500.00

Suspension

All capacities

four months

10/16/2017

2/15/2018

Fines paid in full on September 14, 2018.

WELLS FARGO CLEARING SERVICES, LL

Discharged

Discharged after failing to timely disclose outside activities and financial disclosures.

I had several LLC's that weren't properly dissolved that I never used and was unaware they were still active. I was told I failed to list them on my U4