In a case involving unsuitable variable annuity (VA) transactions, FINRA found that having good procedures and discovering improper conduct are not enough.  A member firm must also ensure that it has adequate supervisory systems in place to ensure that its procedures are properly implemented.  In this case, two of the firm’s registered representatives—who were independent

As baby boomers continue to age, securities regulators focus on protecting the growing population of seniors and retirees. For example, the regulators are seeking to ensure that broker-dealers’ systems and procedures for assessing the suitability of particular types of investments and the mental competence of their customers are adequate. Regulators are also focusing on suitability