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Mike Dowden: Harger and Company Advisor Suspended by FINRA

A disciplinary action taken by the Financial Industry Regulatory Authority against Baton Rouge, Louisiana broker and investment advisor Mike Dowden (CRD# 4089978) suspended him over allegations he submitted partially completed variable annuity transaction forms to his member firm, Harger & Company. Dowden was fined $10,000 and suspended from acting as a broker for two months as a result of these findings.

According to a Letter of Acceptance, Waiver, and Consent (No. 2017055821401) signed in April 2019, Mike Dowden was supervising principal over another representative, Robert Harger, who allegedly allowed his customers to “sign without date partially completed variable annuity… exchange forms” between March 2010 and October 2016. According to FINRA, Harger inputted the missing information into these forms and submitted them to Dowden, who “wrote in a date next to the applicable customer’s undated signature using the date he approved the transaction,” violating NASD and FINRA Rules.

FINRA’s findings state that during the relevant period, Harger and Company’s written supervisory procedures mandated that partial or full annuity surrender transactions be “closely scrutinized… to ensure the new contract’s suitability for the client,” and additionally that the forms “be completed by the recommending representative” and receive the designated supervising principal’s approval—in this instance, Mike Dowden’s. FINRA notes that the firm’s variable annuity exchange form “required that the customer certify, by dated signature, that he/she had read and understood all the general features (and fees)” of the annuities they were surrendering and purchasing. The form additionally required the recommending representative’s certification (also “by dated signature”) that they had performed a review of the form with the supervising principal, and the principal’s certification that they had reviewed the form and determined that the transaction was suitable.

In spite of these requirements, according to FINRA, Harger allowed a customer’s signature of a partially completed exchange form without a date “[o]n 26 occasions.” FINRA states that in these instances, the form omitted information regarding fees and surrender charges. He would later enter that information himself and submit the form for Mike Dowden’s review, according to FINRA, which states that in each of these instances Dowden approved the transactions despite his observation that the clients had not dated their signatures. “Upon approving the transactions,” FINRA’s findings go on, “Dowden altered the VA Exchange Forms by writing in dates for the customers’ signatures, using the date on which he approved the transaction.” FINRA’s findings state that this conduct constituted violations of FINRA rules. As a result of the foregoing conduct, Dowden was issued a fine of $10,000 and a two-month suspension from association with any FINRA member in any and all capacities.

Mike Dowden is currently registered with Harger and Company in Baton Rouge and Alexandria, Louisiana, according to his FINRA BrokerCheck report. His employment history includes MetLife Securities and Metropolitan Life Insurance Company. He holds one state license (Louisiana) and has passed six securities industry qualification examinations.

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