Initiated By
FINRA
Allegations
FINRA RULES 2010, 8210: AS AN AGENCY COMPLIANCE OFFICER FOR HER FIRM'S BRANCH, LAULETTA FAILED TO MEET THE REQUISITE STANDARDS OF COMMERCIAL HONOR AND PRINCIPLES OF TRADE BY FAILING TO REPORT, INVESTIGATE, OR TAKE OTHER ACTION WHEN SHE LEARNED THAT A REGISTERED REPRESENTATIVE HAD ENGAGED IN SELLING AWAY AND WAS INVOLVED IN THE RELATED COMMISSION-HIDING SCHEME. FURTHER, LAULETTA FAILED TO REPORT, INVESTIGATE, OR TAKE OTHER ACTION UPON HEARING THE REPRESENTATIVE INSTRUCT ANOTHER REGISTERED REPRESENTATIVE TO MISLEAD THE FIRM ABOUT HIS SELLING-AWAY ACTIVITIES. FINALLY, WHEN RESPONDING TO A FIRM QUESTIONNAIRE ABOUT THE SELLING AWAY, LAULETTA OMITTED MATERIAL INFORMATION OF WHICH SHE WAS AWARE THAT A COMMISSION-HIDING SCHEME EXISTED, THAT THE SELLING-AWAY ACTIVITIES INVOLVED MORE THAN THE TWO REPRESENTATIVES SHE NAMED IN HER RESPONSE, AND THAT IT INVOLVED THE FIRST REPRESENTATIVE AS WELL. LAULETTA APPEARED FOR SWORN ON-THE-RECORD TESTIMONY WITH FINRA AND PROVIDED FALSE TESTIMONY TO FINRA. LAULETTA FALSELY TESTIFIED THAT, DURING A CALL WITH A REGISTERED REPRESENTATIVE, ANOTHER REPRESENTATIVE DID NOT MAKE ANY SUGGESTIONS TO THE REPRESENTATIVE ABOUT WHAT THE REPRESENTATIVE SHOULD DISCLOSE TO LAULETTA'S MEMBER FIRM ABOUT AN INVESTMENT COMPANY. LAULETTA FALSELY TESTIFIED THAT, DURING THE CALL WITH THE OTHER REPRESENTATIVE, THE REPRESENTATIVE DID NOT INDICATE ANYONE ELSE FROM AN INSURANCE AGENCY, WHICH HOME OFFICE WAS AN OFFICE OF SUPERVISORY JURISDICTION FOR HER FIRM, WAS INVOLVED IN THE INVESTMENT COMPANY. LAULETTA ALSO FALSELY TESTIFIED THAT SHE NEVER SAID, DURING THE CALL, THAT SHE "DIDN'T HEAR" A REGISTERED REPRESENTATIVE'S DIRECTIVE TO ANOTHER REGISTERED REPRESENTATIVE TO MISLEAD HER FIRM, OR THAT SHE WAS "LEAVING THE ROOM."
Resolution
Decision & Order of Offer of Settlement
Bar
Bar (Permanent)
Registration Capacities Affected
All Capacities
Duration
Indefinite
Start Date
12/10/2012
Regulator Statement
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, LAULETTA CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, SHE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.