The Department of Enforcement alleges: SUMMARY 1. In October 2022, Respondent Ishmael Williams, while registered with FINRA through an association with PFS Investments Inc. (CRD No. 10111), falsely certified to the State of New York that he had personally completed the continuing education (CE) required to renew his state insurance license when, in fact, another person had completed that CE on his behalf. As a result of the foregoing, Williams violated FINRA Rule 2010. 2.

Spuhler refused to provide information and documents requested by FINRA pursuant to FINRA Rule 8210. As a result, Spuhler violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

In February and May 2023, Holeman forged the electronic signatures of four customers on a total of eight documents. Therefore, Holeman violated FINRA Rules 2010 and 4511. For these violations, Holeman is suspended in all capacities for 45 calendar days and fined $5,000.