The Department of Enforcement alleges: Between March 2021 and October 2021 (the “relevant period”), respondent Spartan Capital Securities, LLC (“Spartan”) made 346 recommendations of securities that had a total principal value of over $24 million to 191 customers, the majority of whom were retail customers, through 16 private placement offerings (“Offerings”). Spartan lacked a reasonable basis to believe these recommendations were suitable or in the best interest of its customers because it failed to conduct reasonable due diligence on the Offerings.

Between January 2023 and February 2024, Jones initiated 18 electronic transfers from his UBS brokerage account to make payments on a credit card issued by the firm’s affiliated bank, knowing that his brokerage account lacked funds to cover the transfers. Jones immediately made use of the available credit on his credit card, enabling him to spend a total of $29,096 beyond his credit limit. By virtue of this conduct, Jones violated FINRA Rule 2010. Jones is suspended for eight months and fined $7,500.

Between October and December 2021, Holmes recommended options transactions to a customer without having a reasonable basis to conclude that the transactions would be in the customer’s best interest or suitable based on her investment profile. Accordingly, Holmes violated FINRA Rules 2360(b)(19) and 2010, and willfully violated Regulation Best Interest. In August 2020, Holmes submitted account information for the same customer to his employer firm that inaccurately stated her financial circumstances, investment experience, and investment objectives, in violation of FINRA Rules 4511 and 2010.