From May 2016 to October 2022, MDB Capital failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to address certain conflicts of interest and to prevent the misuse of material non-public information (MNPI). Therefore, the firm violated FINRA Rules 3110 and 2010. The firm consents to a censure, a fine of $50,000, and an undertaking to remediate the issues identified in this AWC.