The Department of Enforcement alleges: Respondent Santiago J. Torres, Jr. failed to provide information and documents, and appear for on-the-record testimony, that FINRA requested pursuant to FINRA Rule 8210 as part of an investigation into whether he misappropriated funds and falsified customer documents. By failing to provide the requested information, documents, and testimony, Torres violated FINRA Rules 8210 and 2010.

During August 2023, in anticipation of departing Northwestern, Freeman improperly transferred copies of thousands of files containing customers’ nonpublic personal information from Northwestern’s systems to her personal cloud storage site. The nonpublic personal information included customers’ Social Security and tax identification numbers, state driver’s license and state identification numbers, and financial account numbers. She transferred and retained this information until April 2024 without the customers’ knowledge or consent and in contravention of Northwestern’s procedures.

Between September 2022 and June 2023, Bodi exercised discretion without prior written authorization in connection with 61 transactions in three customer accounts. As a result, Bodi violated FINRA Rules 3260(b) and 2010...