From at least October 2017 to May 2024, MCAP violated FINRA Rules 3110 and 2010 by failing to establish and maintain a system reasonably designed to supervise the firm’s electronic communications. During this period, MCAP’s written procedures failed to identify who was responsible for conducting supervisory reviews of its designated principals’ electronic communications, and the firm allowed certain designated principals to conduct supervisory reviews of their own electronic communications.

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Michael Venturino, Dix Hills, NY, Respondent. DECISION Complaint No. 2021070337501 Dated: April 7, 2026. Registered representative traded in customer accounts without authorization and excessively traded and churned those accounts. Held, findings affirmed, and sanctions modified.

From February 2021 through April 2021, Morris recommended that five retail customers, including four senior customers, invest in GWG L Bonds, which are speculative, unrated corporate bonds. Morris’s recommendations were not in the customers’ best interests based on their investment profiles. Therefore, Morris willfully violated Rule 15l-1(a)(1) under the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rule 2010. For these violations, Morris is suspended for three months in all capacities, fined $10,000, and ordered to pay $5,607 in partial restitution plus interest.