Now You CE It, Now You Don't

July 10, 2014

Continuing Education -- or as it's known in the biz "CE" -- continues to bedevil the men and women charged with taking the damn courses and the online exams. The concept is pretty straightforward. You study the material. You take the exam. Except, you know, Wall Street is a fairly clever place with lots of clever folks, and, in the end, why do the actual studying or that oh so droll test taking when, you know, a few bucks here, a few bucks there, and, voila!, someone else takes the test for you.  C'mon -- isn't that the true spirit of entrepreneurship and innovation?

Case In Point

For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Jennifer A. Tanck submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Jennifer A. Tanck, Respondent (AWC 2012034849802, June 27. 2014).

In 2000, Tanck first became registered, and from 2009 until December 11, 2012, she was registered with FINRA member firm LPL Financial. In May 2012, the AWC asserts that Tanck was a President of Independent Financial Partners, an LPL Office of Supervisory Jurisdiction.The AWC asserts that she had no prior relevant disciplinary history with the Securities and Exchange Commission, any self-regulatory organization or any state securities regulator.

A Couple Of Bucks For Your Trouble

The AWC alleges that Tanck needed to complete continuing education courses for two state insurance licenses, and on May 31, 2012, she asked a subordinate employee, who was a registered compliance coordinator, to complete the two courses for her. In furtherance of that arrangement, the AWC alleges that  Tanck provided to the employee the password for the continuing education courses offered by an outside vendor. After completing the courses on May 31st, the subordinate was purportedly paid $50 by Tanck, in violation of FINRA Rule 2010.

According to online FINRA records as of July 6, 2014, Independent Financial Parners and LPL "Discharged" Tacker on November 19, 2012, based upon the allegation:


In accordance with the terms of the AWC, FINRA imposed upon Tanck a $5,000 finee and a 20-business-days suspension from associating with any FINRA member firm in any and all capacities.

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