From January 2020 to September 2022, Pronovost engaged in an outside business activity by acting as a trustee to the estate of a deceased Cambridge customer without providing prior written notice to Cambridge or Osaic. As a result, Pronovost violated FINRA Rules 3270 and 2010. For this violation, Pronovost is suspended for two months and fined $7,500.

Between July 2020 and February 2021, while associated with MML, Respondent forwarded approximately $12,000 for the benefit of people he did not know to a third party located overseas, despite red flags that the funds may have been related to illegal activity. Therefore. Respondent violated FINRA Rule 2010, is suspended for nine months and fined $10,000.

From at least June 2021 to the present, PNCI failed to establish and maintain a reasonably designed supervisory system, including written supervisory procedures (WSPs), for the surveillance of rates of deferred variable annuity (VA) exchanges. The firm’s supervisory system did not require the firm to determine if its associated persons had rates of effecting VA exchanges that raised for review whether such rates evidenced conduct inconsistent with FINRA rules or the federal securities laws as required by FINRA Rule 2330(d), and did not provide guidance as to how to make that determination.

From February 2017 through December 2022, as head of Canaccord’s trading compliance group, Lorenzo failed to perform certain of his supervisory responsibilities by delegating and assigning the review of surveillance reports to his subordinates without reasonably following through to confirm the reviews were being conducted. He also failed to reasonably investigate red flags that certain of the reviews were not being performed. As a result, Lorenzo violated FINRA Rules 3110 and 2010.

From February 2017 to December 2022, Daly failed to reasonably supervise Canaccord’s surveillance of its securities transactions in violation of FINRA Rules 3110 and 2010 and from at least October 2016 to December 2022 failed to develop and implement an anti-money laundering (AML) compliance program at Canaccord that was reasonably designed to achieve and monitor compliance with the requirements of the Bank Secrecy Act and its implementing regulations, in violation of FINRA Rules 3310 and 2010.