The Department of Enforcement alleges: SUMMARY 1. In October 2022, Respondent Ishmael Williams, while registered with FINRA through an association with PFS Investments Inc. (CRD No. 10111), falsely certified to the State of New York that he had personally completed the continuing education (CE) required to renew his state insurance license when, in fact, another person had completed that CE on his behalf. As a result of the foregoing, Williams violated FINRA Rule 2010. 2.

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

In February and May 2023, Holeman forged the electronic signatures of four customers on a total of eight documents. Therefore, Holeman violated FINRA Rules 2010 and 4511. For these violations, Holeman is suspended in all capacities for 45 calendar days and fined $5,000.

From August 2021 to April 2022, while registered with FINRA through an association with Farmers, Funakura participated in private securities transactions by soliciting nine investors to invest a total of $120,000 in promissory notes issued by a company claiming to operate crypto asset mining and investment programs. By participating in private securities transactions without prior written notice to or approval from Farmers, Funakura violated FINRA Rules 3280 and 2010 and is suspended for six months in all capacities, fined $10,000, and ordered to disgorge $4,000 plus interest.