Broker records

Participated in $4.4 million private offering without firm disclosure or approval

Undisclosed outside business activity and over 400 private securities transactions

Failed to terminate contingency offerings and return investor funds after material changes

Accused of failing to provide documents and testimony in bankruptcy-related examination

Failed to supervise unsuitable margin recommendations to unsophisticated customers

Failed to supervise access to stock plan services account data enabling employee theft

Failed to establish Reg BI and Form CRS compliance systems despite repeated warnings

Failed to evaluate promissory note activity as potential private securities transaction

Engaged in undisclosed private securities transactions totaling $979,500

Conducted unregistered distribution and failed to respond to red flags

Failed to supervise for compliance with MSRB Rule G-37 political contribution rules

Failed to supervise associated persons' outside brokerage accounts