FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2022075597102 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Spartan Capital Securities, LLC (Respondent) Member Firm CRD No. 146251 Pursuant to FINRA Rule 9216, Respondent Spartan Capital Securities, LLC submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2023077782601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Commerce Brokerage Services, Inc. (Respondent) Member Firm CRD No. 17140 Pursuant to FINRA Rule 9216, Respondent Commerce Brokerage Services, Inc. (“Commerce Brokerage”) submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2022077410101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: James C. Stockton (Respondent) Investment Company and Variable Contracts Products Representative and Direct Participation Programs Representative CRD No. 1801686 Pursuant to FINRA Rule 9216, Respondent James C. Stockton submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019063352402 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Tim D. Hemingway (Respondent) General Securities Representative CRD No. 5013252 Pursuant to FINRA Rule 9216, Respondent Tim D. Hemingway submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019063352403 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Walter C. Bish (Respondent) General Securities Representative CRD No. 3214712 Pursuant to FINRA Rule 9216, Respondent Walter C. Bish submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019063352401 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Smith, Brown & Groover, Inc. (Respondent) Member Firm CRD No. 1329 Raymond Hill Smith, Jr. (Respondent) General Securities Representative and General Securities Principal CRD No. 731506 Pursuant to FINRA Rule 9216, Respondents Smith, Brown & Groover, Inc.