From January 2019 through June 2023, Apex entered into securities loans with certain introduced customers without having reasonable grounds to believe that the loans were appropriate for those customers because those customers did not receive a loan fee for lending their shares.

The Department of Enforcement alleges: Respondent Santiago J. Torres, Jr. failed to provide information and documents, and appear for on-the-record testimony, that FINRA requested pursuant to FINRA Rule 8210 as part of an investigation into whether he misappropriated funds and falsified customer documents. By failing to provide the requested information, documents, and testimony, Torres violated FINRA Rules 8210 and 2010.

During August 2023, in anticipation of departing Northwestern, Freeman improperly transferred copies of thousands of files containing customers’ nonpublic personal information from Northwestern’s systems to her personal cloud storage site. The nonpublic personal information included customers’ Social Security and tax identification numbers, state driver’s license and state identification numbers, and financial account numbers. She transferred and retained this information until April 2024 without the customers’ knowledge or consent and in contravention of Northwestern’s procedures.