The Department of Enforcement alleges: Respondent Andrew Paul Schneider failed to respond to two FINRA staff requests to provide information and documents made pursuant to FINRA Rule 8210 as part of FINRA staff’s investigation into possible misconduct by Schneider in connection with an outside business activity. As a result, Schneider violated FINRA Rules 8210 and 2010.

The Department of Enforcement alleges: 1. Between May 2023 and May 2024, Respondent Gerald James O’Halloran recommended that eight retail customers exchange their variable annuities, causing them to incur approximately $144,000 in surrender charges; reducing their contract values; and reducing their death benefits by a combined $173,365.

Between January 2022 and April 2026, DLA violated MSRB Rules G-2 and G-3 by permitting associated persons at two branch offices to supervise municipal securities sales even though they lacked the requisite registrations. For these violations, DLA is censured and fined $15,000.

Between December 2020 and January 2025, Sandeman recommended that 81 retail customers purchase and hold volatility-linked and non-traditional exchange-traded products (ETPs) as long-term investments. Sandeman made these recommendations without a reasonable understanding of the risks associated with the products and without a reasonable basis to believe that the recommendations were in the best interest of his retail customers. As a result, Sandeman willfully violated Rule 151-l(a)(l) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rule 2010.