Between March 2023 and October 2024, Talbot recommended to one retail customer a series of trades that were excessive and not in the customer’s best interest. As a result, Talbot willfully violated the Best Interest Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rule 2010. For these violations, Talbot is suspended for four months in all capacities.

For one partial tender offer (PTO) in 2022, Cowen violated the Securities Exchange Act of 1934 Rule 14e-4(b)(1) and FINRA Rule 2010 by over-tendering 100,000 shares in a partial tender offer of Company 1. In addition, from October 2022 through May 2024, Cowen violated FINRA Rules 3110 and 2010 by failing to have a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with Exchange Act Rule 14e-4. For these violations, Cowen is censured, fined $80,000, of which $40,000 will be paid to FINRA.