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