From November 2015 through June 2023, while associated with Titan, Ondris used an unauthorized personal email account to send and receive securities-related business communications to firm customers. Ondris did not provide copies of the emails to Titan and thereby prevented Titan from preserving the emails as required by Section 17(a) of the Securities Exchange Act of 1934 and Exchange Act Rule 17a-4(b)(4). By causing Titan to maintain incomplete books and records, Ondris violated FINRA Rules 4511 and 2010 and is suspended for one month and fined $5,000.

On December 23. 2022. McCarthy improperly shared confidential information protected by the Bank Secrecy Act (BSA) and U.S. Department of the Treasury regulations implementing the BSA with an individual not authorized to view it. As a result of this conduct, McCarthy violated FINRA Rule 2010.

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. SECURITIES EXCHANGE ACT OF 1934 Release No. 101991 / December 19, 2024 Admin. Proc. File No. 3-20647 In the Matter of the Application of PAUL ERIC FLESCHE For Review of Disciplinary Action Taken by FINRA OPINION OF THE COMMISSION REGISTERED SECURITIES ASSOCIATION — REVIEW OF DISCIPLINARY PROCEEDING Associated person of FINRA member firm appeals from FINRA disciplinary action finding that he failed to reasonably supervise one of the firm’s registered representatives. Held, the proceeding is remanded to FINRA.

Fletcher refused to provide information and documents requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010.