From August 2018 through December 2023, Paulson effected at least 15,000 short sale transactions totaling approximately 64.5 billion shares to facilitate the execution of long sale orders from its broker-dealer clients without obtaining locates, in violation of Rule 203(b)(1) of Regulation SHO and FINRA Rule 2010. In addition, from August 2018 through April 2024, Paulson failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with the locate requirement of Rule 203(b)(1) of Regulation SHO, in violation FI

From June 30, 2020, to the present, Fortrend Securities willfully failed to comply with Form CRS requirements. The firm failed to timely file and deliver its Form CRS to retail investors. When the firm belatedly filed and delivered its Form CRS, it contained deficiencies, including disclosing the wrong clearing firm and associated fees and charges, and omitting other required information. As a result, Fortrend Securities willfully violated Section 17(a)(1) of the Securities Exchange Act of 1934 and Exchange Act Rule 17a-14, and violated FINRA Rule 2010.