From January 2018 through present, SogoTrade failed to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of its market access business activity, including controls designed to prevent the entry of erroneous orders, in violation of Section 15(c)(3) of the Securities Exchange Act of 1934, Exchange Act Rules 15c3-5(b) and 15c3-5(c)(1)(ii), and FINRA Rules 3110 and 2010.

In December 2024, while associated with Osaic Wealth, Botello borrowed a total of $173,000 from two of his customers without obtaining approval from the firm. Therefore, Botello violated FINRA Rules 3240 and 2010. For these violations, Botello is suspended for three months and fined $5,000.

Since June 30, 2020, Carter Terry has failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with the Care Obligation of Rule 15l-1 of the Securities Exchange Act of 1934 (Reg BI) with respect to Unit Investment Trust recommendations. Carter Terry therefore violated FINRA Rules 3110 and 2010.