FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2015048250401 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Transamerica Financial Advisors, Inc. (Respondent) Member Firm CRD No. 16164 Pursuant to FINRA Rule 9216, Respondent Transamerica Financial Advisors, Inc. (TFA) submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019062882101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Calton & Associates, Inc. (Respondent) Member Firm CRD No. 20999 Pursuant to FINRA Rule 9216, Respondent Calton & Associates, Inc. (“Calton,” the “Firm” or “Respondent”) submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019062898302 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Supreme Alliance LLC (Respondent) Member Firm CRD No. 45348 Pursuant to FINRA Rule 9216, Respondent Supreme Alliance LLC submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT No. 2018059223501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Frank H. Zito (Respondent) General Securities Representative CRD No. 2766336 Pursuant to FINRA Rule 9216, Respondent Frank H. Zito submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2016048921103 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: PHX Financial, Inc. (Respondent) Member Firm CRD No. 144403 Robert Delaplain (Respondent) General Securities Principal CRD No. 1017107 Pursuant to FINRA Rule 9216, Respondents PHX Financial, Inc. (PHX) and Robert Delaplain submit this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019064867601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Gautam Arora (Respondent) Former Investment Company and Variable Contracts Product Representative CRD No. 5443201 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Gautam Arora submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018057389701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Citigroup Global Markets Inc. (Respondent) Member Firm CRD No. 7059 Pursuant to FINRA Rule 9216, Respondent Citigroup Global Markets Inc. (CGMI) submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019062973402 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Najib H. Khan (Respondent) Former Investment Company and Variable Contracts Products Representative CRD No. 5771774 Pursuant to FINRA Rule 9216, Respondent Khan submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.