Between January 2023 and February 2024, Jones initiated 18 electronic transfers from his UBS brokerage account to make payments on a credit card issued by the firm’s affiliated bank, knowing that his brokerage account lacked funds to cover the transfers. Jones immediately made use of the available credit on his credit card, enabling him to spend a total of $29,096 beyond his credit limit. By virtue of this conduct, Jones violated FINRA Rule 2010. Jones is suspended for eight months and fined $7,500.

Between October and December 2021, Holmes recommended options transactions to a customer without having a reasonable basis to conclude that the transactions would be in the customer’s best interest or suitable based on her investment profile. Accordingly, Holmes violated FINRA Rules 2360(b)(19) and 2010, and willfully violated Regulation Best Interest. In August 2020, Holmes submitted account information for the same customer to his employer firm that inaccurately stated her financial circumstances, investment experience, and investment objectives, in violation of FINRA Rules 4511 and 2010.

The Department of Enforcement alleges: 1. Respondent Gustave Schmidt failed to disclose compensation related to private placements that he brought to his firm and recommended to his clients, including a fee that exceeded the maximum disclosed amount in the offering documents by fifty percent. Despite this outsized compensation, Schmidt failed to have a reasonable understanding of the risks, rewards, and costs associated with the products he was recommending. 2. Between December 2020 and April 2021, while associated with Investment Network Inc.

From at least January 2016 through April 2022, NSI violated Regulation SHO Rule 200(f) and FINRA Rule 2010 by including securities positions of two affiliates when calculating the net positions of an independent trading unit. In addition, from at least January 2016 through April 2022, NSI violated FINRA Rules 3110 and 2010 by failing to establish and maintain a supervisory system that was reasonably designed to achieve compliance with Rule 200(f). For these violations, NSI is censured, fined $625,000, and required to certify that its business complies with Rule 200(f).

From September 2022 through March 2023, Laidlaw conducted a securities business while failing to maintain the required minimum net capital on at least 108 days and filed two inaccurate notices of net capital deficiency, in violation of Exchange Act §§ 15(c)(3) and 17(a), Exchange Act Rules 15c3-1 and 17a-11, and FINRA Rules 4110(b)(1) and 2010.