Private Placement and Variable Annuity Misrepresentation Finra Arbitration and Litigation Lawyer, Russell L. Forkey, Esq.

January, 2010

TIAA-CREF Individual & Institutional Services, LLC (CRD #20472, New York, New York)  submitted a Letter of Acceptance, Waiver and Consent in which the firm was censured and fined $100,000.  Without admitting or denying the findings, the firm consented to the described sanctions and to the entry of findings that it failed to report quarterly statistical and summary information to FINRA regarding a substantial number of customer complaints. The findings stated that the firm failed to establish, maintain and enforce a supervisory system reasonably designed to identify, capture, analyze and report customer complaints that are required to be reported pursuant to NASD Rule 3070(c). The findings also stated that the firm failed to put adequate systems and procedures in place to ensure that all customer complaints were identified and forwarded to the appropriate firm personnel, failed to adequately train all personnel who might potentially receive customer complaints regarding proper handling of complaints, and failed to ensure that sufficient guidance was given to personnel who were responsible for reviewing complaints to determine which complaints were reportable. (FINRA Case #2007011343301).