August 2, 2022 – An AWC was issued in which Wilkie (CRD #467130) was assessed a deferred fine of $10,000 and suspended from association with any FINRA member in all capacities for six months. Without admitting or denying the findings, Wilkie consented to the sanctions and to the entry of findings that he circumvented his member firm’s policies requiring disclosure and approval of his beneficiary status on a customer’s life insurance policy. The findings stated that Wilkie entered into an agreement with an insurance customer to pay 60 percent of the premiums on the customer’s life insurance policy in exchange for the same percentage of the death benefit. The customer subsequently named Wilkie as a beneficiary on the policy, and Wilkie paid the premiums as agreed. Wilkie nonetheless failed to disclose his beneficiary status to the firm and denied on the firm’s annual compliance questionnaire that he had been named as a beneficiary on a customer’s insurance policy. In order to further conceal his activity, Wilkie caused the customer to change the beneficiary from Wilkie to Wilkie’s son. Although Wilkie was removed as a beneficiary on the policy, the customer, Wilkie, and his son, agreed that Wilkie would still receive the death benefit. Upon the customer’s death, the insurance company paid a $125,000 death benefit to Wilkie’s son, who then transferred the funds to Wilkie.
The suspension is in effect from August 15, 2022, through February 14, 2023. (FINRA Case #2021070774101)