Unapproved Outside Business and Selling Away FINRA Arbitration and Litigation Attorney, Russell L. Forkey, Esq.
Stephen Johnathan Hoshimi (CRD #1977772, Registered Principal, Pacific Palisades, California) submitted a Letter of Acceptance, Waiver and Consent in which he was suspended from association with any FINRA member in any capacity for six months. In light of Hoshimi’s financial status, no monetary sanctions have been imposed. Without admitting or denying the findings, Hoshimi consented to the described sanction and to the entry of findings that he entered into an arrangement with a registered investment advisor that was not a FINRA member, whereby he would receive orders from the registered investment advisor’s customers who wished to purchase promissory notes and would effect the purchases through his member firm. The findings stated that Hoshimi purchased promissory notes for the investment advisor’s customers for a total of approximately $1,000,000. Hoshimi paid the investment advisor approximately $23,825 in transaction based compensation, thereby sharing his commissions with the investment advisor. The findings also stated that Hoshimi engaged in private securities transactions without prior written notice to and approval from his firm; he participated in life settlement transactions in which his customers sold fixed life insurance policies to settlement brokers for a total of approximately $390,855. The findings also included that Hoshimi engaged in outside business activities without providing prompt written notice to his member firm; he participated in life settlement transactions in which his customers sold variable life insurance policies to settlement brokers for a total of approximately $1,152,033 for which he received approximately $325,422 in commissions. FINRA found that Hoshimi engaged in private securities transactions without prior written notice to and approval from his firm; he effected purchases of stocks as his own personal investments for a total of approximately $139,500.
The suspension is in effect from December 19, 2011, through June 18, 2012. (FINRA Case #2008014855301