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.

From July 2020 through June 2023, Dagostino recommended that retired and senior investors purchase speculative and low-priced securities. Such recommendations subjected the customers to a substantial risk of loss, which was inconsistent with their investment profiles and therefore not in their best interests. As a result, Dagostino willfully violated the Care Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rule 2010, and he is suspended for 24 months and fined $25,000.