BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Alpine Securities Corporation, Salt Lake City, UT, Respondent. DECISION Complaint No. 2019061232601 Dated: March 25, 2025. Member charged an unreasonable and unfairly discriminatory fee, made unauthorized securities transactions, misused and converted customer assets, priced securities trades unfairly, and made an unauthorized capital withdrawal. Held, findings affirmed in part and modified, and sanctions modified.

Palma refused to produce information and documents requested pursuant to FINRA Rule 8210. As a result, Palma violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

From April 2019 to June 2022, UFP and Dickerson failed to establish and maintain a reasonable supervisory system, including written procedures, reasonably designed to supervise the outside brokerage accounts disclosed by its registered representatives pursuant to FINRA Rule 3210.

From March 2020 to January 2023, Copeland participated in 74 private securities transactions without providing prior written notice to his firm. Copeland recommended the securities to 27 individuals, most of whom were LPL customers. Collectively, the customers invested nearly $11 million in 19 securities to fund real estate development projects and investments in other businesses.