From August 2021 to April 2022, while registered with FINRA through an association with Farmers, Funakura participated in private securities transactions by soliciting nine investors to invest a total of $120,000 in promissory notes issued by a company claiming to operate crypto asset mining and investment programs. By participating in private securities transactions without prior written notice to or approval from Farmers, Funakura violated FINRA Rules 3280 and 2010 and is suspended for six months in all capacities, fined $10,000, and ordered to disgorge $4,000 plus interest.

From July 2020 to June 2023, Merrill Lynch accepted market orders for the purchase of shares of equity new issues in the secondary market prior to the commencement of trading of such shares in the secondary market.

From January 2020 through December 2022, while associated with Vanderbilt, Trask exercised discretionary authority without prior written authorization in connection with at least 675 transactions in four customers' accounts. As a result, Trask violated FINRA Rules 3260(b) and 2010 and is suspended for 30 calendar days and fined $5,000.

Gallagher refused to provide documents and information and to appear for on-the-record testimony requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010.