Broker Thomas R. Fortino submitted a Letter of Acceptance, Waiver and Consent to settle rule violations alleged by FINRA. Fortino worked for several FINRA member firms, including three stints at First Allied Securities Inc., since he entered the securities industry in 1995. Fortino was permitted to resign from First Allied in July 2010 for failing to disclose outside business activities and referrals. FAS prohibited outside equity indexed annuities sales for a period from January 2007 to July 2010, and required authorization prior to engaging in any outside insurance sales. At least $68,843 of Fortino’s $334,764.93 transactional-based earnings during the period was attributable to EIA sales. Fortino was issued a Letter of Caution in April 2009 for unapproved EIA sales. Fortino made three subsequent unapproved EIA sales. In accordance with the AWC, FINRA imposed upon Fortino a $15,000 fine and a 10-month suspension from associating with any FINRA member firm in any capacity.