Fraud, Selling Away and Negligent Supervision FINRA Arbitration and Litigation Attorney, Russell L. Forkey, Esq.

October, 2011:

Clyde Allen Benninghoff (CRD #18463, Registered Principal, Amelia Island, Florida)

submitted a Letter of Acceptance, Waiver and Consent in which he was barred from association with any FINRA member in any capacity. Without admitting or denying the findings, Benninghoff consented to the described sanction and to the entry of findings that he facilitated securities investments away from his member firm. The findings stated that individuals, who were not customers of Benninghoff’s firm, invested a total of $1,560,531.80 in a secured premium finance plan, which purported to promise a 12 percent return on an accompanying promissory note. The findings also stated that the secured premium finance plan was marketed as an investment that included financing for premiums on life insurance policies. The findings also included that Benninghoff wrote the life insurance policies through his firm’s life insurance company affiliate. FINRA found that the investments were not made through Benninghoff’s firm and were unknown to the firm. FINRA also found that Benninghoff did not provide written notice to, or obtain approval from, his firm prior to facilitating the investments. In addition, FINRA determined that Benninghoff failed to appear for a FINRA on-the-record interview. (FINRA Case #2009019487201).