Between June 2021 and July 2023, while associated with M Holdings, Rapp engaged in an outside business activity involving a private equity fund he co-founded, and for which he served as chief executive officer and managing partner, without providing prior written notice to his firm, in violation of FINRA Rules 3270 and 2010. During the same period, Rapp participated in a private securities offering for the fund without providing prior written notice to his firm, in violation of FINRA Rules 3280 and 2010. For these violations, Rapp is suspended for 21 months and fined $20,000.

From January 2022 through February 2023, Adams forged or falsified the electronic signatures of seven customers and two registered representatives on nine documents, including three documents that were required books and records of the firm. Therefore Adams violated FINRA Rules 2010 and 4511. Adams is suspended for two months in all capacities and fined $5,000.