Lemaire refused to provide information and documents requested pursuant to FINRA Rule 8210 in connection with FINRA’s investigation into whether Lemaire improperly borrowed funds from senior customers. As a result, Lemaire violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

On November 6, 2024, while taking the Series 66 Uniform Combined State Law Examination (a North American Securities Administrators Association (NASAA) qualification exam), Donovan had access to unauthorized materials in violation of FINRA Rule 2010. Donovan is suspended for 18 months in all capacities and fined $5,000.