Selling Away and Outside Business Activity FINRA Arbitration and Litigation Attorney, Russell L. Forkey, Esq.
Robert Mark Benning (CRD #2002792, Registered Representative, Streator, Illinois) submitted an Offer of Settlement in which he was barred from association with any FINRA member in any capacity. Without admitting or denying the allegations, Benning consented to the described sanction and to the entry of findings that he sold investment contracts called Universal Lease Programs (ULPs), and failed to provide written notice to his member firm and failed to receive the firm’s written approval; Benning received at least $38,460 in compensation from his sales of ULPs. The findings stated that Benning failed to disclose his sale of ULPs to FINRA when he was questioned about his outside business activities, private securities transactions and compensation earned for three years. Benning later admitted that he earned income from ULPs sales. The findings also stated that Benning failed to fully and accurately respond to FINRA requests for information. (FINRA Case #2009016709020).