Between October 2019 and April 2021, Wall Street Access (WABR) violated Rule 611(c) of Regulation National Market System (NMS) of the Securities Exchange Act of 1934 and FINRA Rule 2010 by failing to take reasonable steps to establish that the intermarket sweep orders (ISOs) it routed to certain market centers met the requirements for an ISO. The firm also failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to prevent trade-throughs, in violation of Rule 611(a) of Regulation NMS and FINRA Rules 3110 and 2010.

Between at least July 2020 through November 2023, while associated with Morgan Stanley, Head converted over $498,000 from two firm customers for his personal use, violating FINRA Rules 2150(a) and 2010.

Between September 2018 and December 2020, Turner recommended trading in accounts held by three customers that was excessive, unsuitable, and not in their best interest. By this conduct, Turner willfully violated Rule 15-l(a)(1) under the Securities Exchange Act of 1934 (Reg BI) (for conduct on and after June 30, 2020), violated FINRA Rule 2111 (for conduct prior to June 30, 2020), and violated FINRA Rule 2010.