Plp Advisors, Llc

Allegations: AFTER REVIEWING THE VARIABLE LIFE SETTLEMENT TRANSACTIONS EXECUTED BY THE FIRM IN 2005 AND 2006 AS PART OF ITS ROUTINE CYCLE AUDIT, FINRA ALLEGED THAT THE FIRM, THROUGH MR. TUBBERGEN ACTING AS A REGISTERED REPRESENTATIVE ON ONE LIFE SETTLEMENT TRANSACTION, MAY HAVE VIOLATED NASD RULES 2440 AND 2110 AND IM 2440 WHICH COLLECTIVELY ALLEGE UNREASONABLE COMPENSATION, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES. Status: Final Sanction Detail: TOTAL RESTITUTION WAS $77,800 OF WHICH $52,647 WAS LEVIED TO MR. TUBBERGEN AND PAID IN FULL MARCH 15, 2011. Summary: UPON FIRST BECOMING AWARE OF FINRA'S CONCERN IN MAY 2007 THAT THE LIFE SETTLEMENT INDUSTRY'S FORMULATIC APPROACH TO CALCULATING COMPENSATION ON VARIABLE LIFE SETTLEMENT BEING USED BY THE FIRM, AND THEREFORE MR. TUBBERGEN, IN ITS INITIAL TRANSACTIONS COULD BE DEEMED, IN FINRA'S VIEW, EXCESSIVE UNDER THE CIRCUMSTANCES, THE FIRM PROMPTLY MODIFIED ITS APPROACH. THE FIRM CONDUCTED SEVEN OTHER VARIABLE LIFE SETTLEMENT CASES AFTER FINRA RAISED ITS INITIAL CONCERN. NONE OF THOSE CASES RAISED ANY REGULATORY CONCERN. ALL OF THE FIRM'S VARIABLE LIFE SETTLEMENT CASES WERE COMPLETED PRIOR TO THE PUBLICATION OF FINRA'S NOTICE TO MEMBERS 09-42, RELEASED IN JULY 2009 SPECIFICALLY APPLYING RULES 2440 AND 2110 TO VARIABLE LIFE SETTLEMENTS FOR THE FIRST TIME.