FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018056386601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Chapin, Davis, Respondent Member Firm CRD No. 28116 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Chapin, Davis ("Chapin, Davis" or the "Firm") 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. 2018057240801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Alan H. New, Respondent Former Investment Company and Variable Contracts Products Representative CRD No. 2892508 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Alan H. New submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.