If you are a Sacramento-area educator or other retail customer who bought a variable annuity, or swapped one annuity for another, through a small Roseville brokerage, a FINRA action against The Logan Group Securities may sound familiar. On July 27, 2026, FINRA accepted a Letter of Acceptance, Waiver and Consent (AWC) in which The Logan Group Securities (CRD# 40259), a sole proprietorship that BrokerCheck lists under Kevin Christopher Logan, consented to a censure, a $70,000 fine, and an undertaking to fix its supervisory system. According to the AWC, the firm “willfully violated Rule 15l-1 under the Securities Exchange Act of 1934 (Regulation Best Interest or Reg BI)” and failed to reasonably supervise its deferred variable annuity recommendations. BrokerCheck records show the firm is still registered and answer the question whether it is currently suspended with any regulator “No.”
BrokerCheck records show that the firm’s record contains 3 regulatory events, which BrokerCheck lists as final: the 2026 FINRA AWC, a 2023 California Department of Financial Protection and Innovation consent order, and a 2021 FINRA AWC that also concerned variable annuities. There are no customer disputes on the firm’s report.
What FINRA found: no Reg BI procedures at first, missing customer profile information, and undocumented principal review
According to the AWC, “The Logan Group became a FINRA member in April 1996. The firm is a sole proprietorship with its office (and only branch location) in Roseville, California. The firm has two registered representatives and primarily sells mutual funds and deferred variable annuities to retail customers.” BrokerCheck records list the firm’s main office in Granite Bay, CA and list Kevin Christopher Logan as “SOLE PROPRIETOR, CHIEF COMPLIANCE OFFICER” since 01/1996. The AWC states that “This matter originated from a FINRA examination of The Logan Group in 2021.”
Broker-dealers have been required to comply with Regulation Best Interest since June 30, 2020. The AWC describes the firm’s procedures after that date this way: “From June 30, 2020, to August 2021, the firm had no written policies and procedures, including WSPs, addressing Reg BI. Between August 2021 and November 2021, the firm’s Reg BI WSPs provided only general information regarding the purpose of Reg BI and did not describe how to prevent, detect, or promptly correct violations of Reg BI or to otherwise achieve compliance with Reg BI.”
The revised procedures did not fix the core problem. Reg BI’s Care Obligation requires a reasonable basis to believe a recommendation is in the customer’s best interest based on the customer’s investment profile, which the AWC notes includes “the customer’s age, other investments, financial situation and needs, tax status, investment objectives, investment experience, investment time horizon, liquidity needs, risk tolerance”. According to the AWC, the firm’s November 2021 procedures relied on a Client Account Form but “were not reasonably designed to consistently obtain and analyze enough customer information to have a reasonable basis to believe that recommendations to purchase or exchange variable annuities are in the best interest of the particular retail customer. As a result, between November 2021 and December 2024, the firm failed to collect and consider customer profile information in connection with certain recommended deferred variable annuity purchases or exchanges.”
The AWC also addresses how customers were told about annuity costs. According to the AWC, “The Client Account Form did not detail features of the recommended deferred variable annuities such as (1) the surrender period; (2) surrender fees; and (3) applicable continuing fees (including mortality and expense fees).” The AWC adds: “For example, from March 2021 to present, the firm did not utilize the Client Account Form to document disclosure and suitability determinations for approximately a third of the variable annuity purchase and exchange recommendations made by the firm.” FINRA found that “the firm lacked a reasonable basis to believe that all of its customers were informed of such features, as required by Rule 2330(b)(1)(A)(i).”
FINRA Rule 2330(c) requires a registered principal to review each recommended deferred variable annuity purchase or exchange and to document and sign that determination. That review was not documented either. The AWC states that “The Logan Group also failed to document principal review and approval of deferred variable annuity applications submitted from March 2021 to present, contrary to the requirements in Rule 2330(c).”
A Form CRS that denied the firm’s disciplinary history
Form CRS is the short relationship summary a brokerage must give retail customers, and it must answer whether the firm or its professionals have legal or disciplinary history. According to the AWC, “Although the firm first filed its Form CRS in October 2020, the firm did not deliver Form CRS to its retail investors until September 2021.” The AWC states that between April 16, 2021, and July 2023, the firm’s Form CRS stated: “Do you or your financial professionals have legal or disciplinary history? No, neither myself or anyone in the firm have any legal or disciplinary history.” By then, the firm had already settled a FINRA matter on March 17, 2021. The AWC states that “The firm did not update its Form CRS to disclose the firm’s disciplinary history until July 14, 2023.”
The sanctions
According to the AWC, the firm consented to “a censure”, “a $70,000 fine”, and an undertaking that “within 180 days of the date of the notice of acceptance of this AWC, a member of Respondent’s senior management who is a registered principal of the firm shall certify in writing that, as of the date of the certification, the firm has remediated the issues identified in this AWC”. In its sanctions considerations, the July 2026 AWC notes that “in May 2026, The Logan Group engaged a consultant who is in the process of reviewing the adequacy of the firm’s WSPs and supervisory system for compliance with Reg BI and FINRA Rule 2330.” BrokerCheck records state “FINE PAID IN FULL ON AUGUST 11, 2026.”
The firm consented to the findings without admitting or denying them. The AWC states that “this settlement includes a finding that it willfully violated Section 17(a)(1) and Rules 15l-1(a)(1) and 17a-14 of the Securities Exchange Act of 1934” and that this makes the firm “subject to a statutory disqualification with respect to membership.” BrokerCheck records answer the question whether the order constitutes a final order based on violations of laws that prohibit fraudulent, manipulative, or deceptive conduct with “No.” The AWC does not order restitution to any customer.
The firm’s earlier variable annuity AWC and the California order
The 2026 action is the firm’s second FINRA settlement over variable annuities. According to the 2026 AWC, “On March 17, 2021, The Logan Group entered into an AWC in which it consented to a $15,000 fine and censure for, among other things, failing to establish, maintain and enforce written supervisory procedures reasonably designed to achieve compliance with FINRA rules concerning investment recommendations of multi-share class variable annuities”. BrokerCheck records list that matter as FINRA case 2018056455201 with a fine of $15,000.00, and the findings included that “THE FIRM FAILED TO COLLECT THE INVESTMENT OBJECTIVE AND RISK TOLERANCE INFORMATION FOR SOME L-SHARE CONTRACT CUSTOMERS.”
The 2021 AWC describes who the firm’s customers were: “The Logan Group specializes in retirement planning for educators in the greater Sacramento area.” That AWC states that “The Logan Group primarily sells mutual funds and variable annuities to educators through salary deferred 403(b) accounts.” and that “Variable annuity sales accounted for approximately 80% of the firm’s business between October 2017 and September 2018.”
BrokerCheck records also show a California Department of Financial Protection and Innovation (DFPI) consent order, ENF. NO. 34409, with a $2,500.00 penalty and a desist and refrain order. The firm’s own description of that matter is: “FAILURE TO FILE ANNUAL AMENDMENT TO FORM ADV FOR INVESTMENT ADVISOR AND FAILURE TO REPORT ON THAT FORM THE FINRA AWC WHEN IT WAS ENTERED ON 3/17/2021.” A broker-reported DFPI action, initiated 05/27/2022 and resolved with a $2,500 penalty and a desist and refrain order, appears on the individual BrokerCheck report of Kevin C. Logan (CRD# 2052765), who BrokerCheck records show has been registered with the firm since 04/25/1996.
Why deferred variable annuities in 403(b) accounts draw scrutiny
A deferred variable annuity wraps mutual-fund-style subaccounts in an insurance contract. According to the SEC’s investor guidance on variable annuities, these contracts carry insurance charges such as mortality and expense fees, optional benefit fees for features like enhanced death and living benefits, and a surrender charge that “often declines gradually over a period of several years.” Several of those are features the AWC says the firm’s Client Account Form did not detail: the surrender period, the surrender fees, and the continuing fees.
The 2021 AWC states that the firm sold variable annuities to educators through 403(b) accounts; the 2026 AWC does not say which account types were involved in the later recommendations. The SEC’s investor guidance states: “If you invest in a variable annuity through a tax-advantaged retirement plan, such as an IRA or a 401(k) plan, you get no additional tax advantage from the variable annuity.” FINRA Rule 2330(b)(1)(B) requires a firm recommending an exchange to consider whether the customer would incur a surrender charge, be subject to a new surrender period, or lose existing benefits such as death or living benefits. Reg BI requires a reasonable basis to believe the recommendation is in the customer’s best interest based on the customer’s investment profile, and Rule 2330 requires a reasonable basis to believe the customer has been informed of the annuity’s features. The AWC found that, between November 2021 and December 2024, the firm failed to collect and consider customer profile information for certain recommended purchases or exchanges, and that from March 2021 on it did not use the Client Account Form to document disclosure and suitability determinations for approximately a third of its variable annuity purchase and exchange recommendations.
The rules that apply
Recommendations made on or after June 30, 2020, fall under SEC Regulation Best Interest (17 C.F.R. § 240.15l-1). Its care obligation requires a reasonable basis to believe a recommendation is in the retail customer’s best interest based on that customer’s investment profile, and its compliance obligation requires written policies and procedures reasonably designed to achieve compliance. FINRA Rule 2330 governs recommended deferred variable annuity purchases and exchanges: it requires a reasonable basis to believe the customer has been informed of the annuity’s features, consideration of surrender charges and lost benefits on an exchange, and documented review by a registered principal. FINRA Rule 3110 requires a reasonably designed supervisory system, and FINRA Rule 2010 requires high standards of commercial honor. Exchange Act Rule 17a-14 governs Form CRS.
For California customers, Insurance Code section 10509.914, which governed annuity recommendations made before January 1, 2025 (a best-interest standard in section 10509.9200 and following applies to later transactions), required reasonable grounds to believe an annuity recommendation was suitable based on the consumer’s suitability information, which section 10509.913 defines to include age, annual income, and liquidity needs; for FINRA broker-dealer sales, section 10509.914(h) treats compliance with FINRA Rule 2330 as satisfying those requirements if the suitability criteria also include the consumer’s income and the intended use of the annuity. Where a customer was 65 or older at the time of the transaction, the Welfare and Institutions Code defines financial elder abuse at section 15610.30 and provides enhanced remedies at section 15657.5. Under FINRA Rule 12206, “No claim shall be eligible for submission to arbitration under the Code where six years have elapsed from the occurrence or event giving rise to the claim.”
What The Logan Group’s customers can do
A FINRA fine goes to FINRA, not to customers, and this AWC does not order restitution. Recovery, if any, depends on customers bringing their own claims. Depending on the facts, claims in FINRA arbitration may seek damages such as surrender charges paid on an exchange, annuity fees, and investment losses. Where California’s elder abuse statutes apply, enhanced remedies may be available. Each claim depends on the facts of the specific purchase or exchange, so the documents matter.
Steps to Take Right Now
- Gather your account statements, trade confirmations, and any correspondence with your broker or firm, including emails, texts, and written materials about the investments.
- Look up your broker on FINRA BrokerCheck at brokercheck.finra.org to review their full disclosure record.
- Contact a securities arbitration attorney for a consultation to evaluate your options.
Rosenberger + Kawabata represents retail investors in FINRA arbitration proceedings involving unsuitable deferred variable annuity recommendations and violations of Regulation Best Interest. Contact Rosenberger + Kawabata online for a confidential consultation, or call (310) 894-6921.
The information in this post comes from FINRA’s public records and BrokerCheck database. You can view the full detailed report (CRD# 40259) here.
You can view the full September 2026 FINRA disciplinary actions report here.