Since 2019, Aegis has paid several million dollars to its corporate parent and recorded those payments as expenses, rather than properly accounting for those payments in net capital computations and FOCUS filings as distributions. As a result, Aegis kept inaccurate books and records in violation of Securities Exchange Act of 1934 § 17(a) and Rules 17a-3 and 17a-5, and FINRA Rules 4511 and 2010. Aegis also failed to reasonably supervise the preparation of its books and records in violation of FINRA Rules 3110 and 2010.

Bienvenu refused to provide information and documents requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010. For these violations, Bienvenu is barred from associating with any FINRA member in all capacities.