Selling Away and Unapproved Outside Business Activity FINRA Arbitration and Litigation Attorney, Russell L. Forkey, Esq.

November, 2011:

Joel Arthur Hulke (CRD #2333013, Registered Representative, North Mankato, Minnesota) was barred from association with any FINRA member in any capacity. The sanction was based on findings that Hulke failed to respond to FINRA requests for information and on-the-record testimony. The findings stated that Hulke engaged in outside business activities through his association with an insurance company, but failed to notify his firm of this relationship or submit the required outside business activity disclosure form. The findings also stated that the firm uncovered Hulke’s association with the insurance company when it investigated Hulke’s reversal of a customer’s purchase of a fixed annuity entered through the firm; the firm discovered that Hulke had executed the same fixed annuity transaction for the same customer through the insurance company. The findings also included that Hulke received a commission for the purchase of the fixed annuity executed through the insurance company; the firm also discovered several other instances where Hulke sold annuity and life insurance policies to customers that resulted in additional commission payments to him outside of his firm. (FINRA Case #2009018295601).