From at least September 2014 through at least July 2023, BofAS violated Exchange Act Rules 611(a)(1), (a)(2) and (c), and FINRA Rules 6380A(a)(5)(I) and (J), and 2010 by, among other things, failing to establish, maintain, and enforce written policies and procedures reasonably designed to prevent trade-throughs of protected quotations in NMS stocks resulting from system issues and assure that its intermarket sweep orders (ISOs) complied with Regulation NMS.

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. PETER J. FETHERSTON (CRD No. 2108610), Respondent. Disciplinary Proceeding No. 2020065396501 Hearing Officer–BDC EXTENDED HEARING PANEL DECISION FOLLOWING REMAND October 22, 2025 For failing to respond to a FINRA request for information, as alleged in cause three, Peter J. Fetherston is barred in all capacities from associating with any FINRA member firm.

At certain times between April 2020 and November 2022, Vision failed to accurately calculate its required customer reserve and its required reserve for proprietary accounts of broker-dealers (PABs). The firm's inaccurate calculations on these occasions caused its reserve accounts to be underfunded, resulting in hindsight deficiencies. This also caused the firm co maintain inaccurate books and records and to file inaccurate Financial and Operational Combined Uniform Single (FOCUS) reports.