Respondent Christopher Cacace is fined $5,000, suspended in all supervisory capacities for 30 business days, and required to requalify as a General Securities Principal for failing to fulfill his supervisory responsibility to reasonably respond to red flags of excessive trading by four registered representatives, in violation of FINRA Rules 3110 and 2010.

Routie refused to appear for on-the~record testimony as requested pursuant to FINRA Rule 8210 in connection with a FINRA investigation into whether he bonowed money from customers. As a result, Routie violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

Between July 2019 and January 2023, Flow Traders inaccurately reported over 103,000 transactions to the Trade Reporting and Compliance Engine (TRACE) without the required No Remuneration (NR) indicator, in violation of FINRA Rules 6730(d)(1) and (d)(4)(F) and 2010. During the same period, Flow Traders also failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with FINRA Rules 6730(d)(1) and (d)(4)(F), in violation of FINRA Rules 3110(a), 3110(b), and 2010.

From June 2023 to September 2023, in anticipation of leaving RJA for a new firm, Nevels improperly took confidential and proprietary information from RJA 's systems, including nonpublic information about RJA 's customers, by emailing it to his personal email address, by printing and retaining documents, and by retaining pictures taken of RJA's system. This information was directly relevant to Nevels' new position, and he accessed some of the information after moving to the new firm . This conduct violated RJA 's policies by which he had agreed to abide.

Fiallo refused to provide documents and information requested pursuant to FINRA Rule 8210. As a result, he violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.