From January 2018 to at least January 2024, Mundial Financial Group allowed its indirect owner, who was not registered with FINRA in any capacity, to engage in securities activities requiring registration in violation of FINRA Rules 1210 and 2010 and NASD Rules 1021 and 1031.2 From September 2019 to the present, the firm failed to develop and implement an anti-money laundering (AML) compliance program reasonably designed to achieve and monitor the firm’s compliance with the Bank Secrecy Act and its implementing regulations in violation of FINRA Rules 3310(a), 3310(b), 3310(f), and 2010.

Okuma refused to provide information and documents requested pursuant to FINRA Rule 8210 in connection with an investigation into whether he converted funds of an elderly customer. As a result, Okuma violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

From January 2020 to September 2023, BofA Securities published 15 quarterly reports regarding customer orders in NMS securities pursuant to Rule 606 of Regulation National Market System (NMS) under the Securities Exchange Act of I 934 that provided inaccurate and incomplete information. As a result, the firm violated Rule 606(a) of Regulation NMS and FJNRA Rule 2010. During the same period, BofA Securities failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with Rule 606.

From January 2022 to June 2023, Clear Street routed options orders for execution with inaccurate origin codes, resulting in the execution of 988,170 options contracts with an origin code of “Customer” that should have been coded “Professional Customer.” These inaccurate origin codes were contained in the firm’s books and records. Therefore, the firm violated Section 17(a) of the Securities Exchange Act of 1934, Exchange Act Rule 17a-3(a)(6)(i), and FINRA Rules 4511 and 2010.

From January 2020 to December 2023, Garrido exercised discretion without written authorization in connection with approximately 2,500 trades in over 200 customer accounts in violation of FINRA Rules 3260(b) and 2010. Additionally, from January 2020 to August 2024, he used his personal cell phone to exchange thousands of securities business-related text messages with customers, causing A.G.P. / Alliance Global Partners to maintain incomplete records of business communications in violation of FINRA Rules 4511 and 2010.