FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018057629501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: James R Willing, Respondent General Securities Representative CRD No. 468560 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent James Robert Willing submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.