FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICE Disciplinary Proceeding No. 2021071987902 Department of Enforcement, Complainant, v. Sutter Securities, Inc., CRD No. 30770 and Keith Charles Moore, CRD No. 5191450 Respondents. COMPLAINT The Department of Enforcement alleges: SUMMARY Between March 2020 and July 2021 (the relevant period), Respondent Sutter Securities Inc. (Sutter), acting through a former Sutter registered representative (Representative1), recommended and effected 2,217 trades in two accounts belonging to a retired, 89-year-old customer (Customer 1).

It has been determined that the Offer be accepted and that findings be made as follows: Respondent James Thaddeus Walesa failed to respond to two FINRA staff requests to provide information and documents, and another two requests to appear for on-the-record testimony, made pursuant to FINRA Rule 8210 as part of FINRA Staff’s examination into Walesa’s business practices, his voluntary termination from Arkadios Capital, and allegations made against Walesa in [Customer B & Customer Family Trust] v. Arkadios Capital & James Thaddeus Walesa, FINRA 23-03184, (Nov.