BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Jose L. Centeno, Nutley, NJ, Respondent. DECISION Complaint No. 2020066079903 Dated: September 30, 2025. Registered representative and principal entered false information in firm records to reflect that he had reviewed exception reports when, in fact, he had not reviewed them. Held, findings of violation modified and sanctions affirmed.

From May 2022 to June 2023, Lannister exercised discretion without written authorization in three accounts held by two customers. As a result, Lannister violated FINRA Rules 3260(b) and 2010 and is suspended in all capacities for two months and fined $5,000.

From December 2019 through the present, Velocity violated FINRA Rules 3110 and 2010 by failing to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with rules prohibiting manipulative trading activity by its customers. For this violation, Velocity has agreed to a censure, a $1,000,000 fine, and an undertaking to hire an independent consultant...

Girgis refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210 in connection with an investigation into Girgis’s outside business activities and his trading activity in his Worden Capital and SW Financial customers’ accounts. As a result, Girgis violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities...

Between January 2018 and December 2019, the firm’s supervisory system, including written supervisory procedures (WSPs), was not reasonably designed to supervise trading at the firm by a senior executive and principal in violation of FINRA Rules 3110 and 2010. In addition, between January 2018 and February 2019, UCM distributed eight retail communications to investors or potential investors that had not been subject to prior review and approval by an appropriately qualified principal. Moreover, these communications contained language that was exaggerated and which was not fair and balanced.

SUMMARY On June 24 and 28, 2022, Sean Sullivan placed 14 trades whose principal value totaled more than $250,000 in the accounts of four customers without their authorization, in violation of FINRA Rule 2010. 2. From April 2 to July 28, 2022, Sullivan willfully failed to timely amend his Uniform Application for Securities Industry Registration or Transfer (Form U4)...

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Paul Eric Flesche, Sherman Oaks, CA, Respondent. DECISION Complaint No. 2016049565901r Dated: September 24, 2025. On remand from the Securities and Exchange Commission. Held, findings of violations dismissed and sanctions reversed.

Between January 2022 and October 2024 (the relevant period), Interactive Brokers failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with the firm's obligation to disclose to customers, at or prior to the time of trade, all material information concerning municipal securities transactions, including instances in which a municipal bond is trading at a market discount.