Individuals trading securities must pass exams administered by FINRA to become registered representatives.

Marc E. Lackritz, the president of the Securities Industry Association, said the S.E.C. had only found 40 individuals with sales practice problems, while the nine companies employ 50,762 registered representatives.

All three men went back to school at night to study for the tests they would take to become registered representatives empowered to buy and sell stocks.

The firm's chief stock trader and 11 of its registered representatives were also named in the indictment.

This enables the company to distribute its variable products through independent registered representatives, registered investment advisors, banks, and wire houses.

FINRA is funded primarily by assessments of member firms' registered representatives and applicants, annual fees paid by members, and by fines that it levies.

Worthen failed to keep copies of all customer letters and failed to maintain an adequate system to supervise its registered representatives, it said.

Lincoln Savings Bank in New York has a private banking unit, only a year old, with several registered representatives who make customer contacts and then turn them over to the bank's brokerage unit.

We prefer to grow our own registered representatives.

"We now have 72 registered representatives in our three Westchester offices and we've taken on six trainees who are going to school for nine weeks from 8:30 to 5," he said.