FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019063532901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) Ramon Esparza, Respondent Investment Company and Variable Contracts Products Representative CRD No. 5832979 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Ramon Esparza submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018058061801 TO; Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: John Carneglia, Respondent Registered Representative CRD No. 4404911 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent John Carneglia submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing settlement of the alleged rule violations described below. This AWC is submitted on the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2016050508501 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Oppenheimer & Co. Inc., Respondent Member Firm CRD No. 249 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Oppenheimer & Co. Inc. (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. This AWC is submitted

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant, v. Mercer Hicks III (CRD No. 245170), Respondent. Disciplinary Proceeding No. 2017052867301 COMPLAINT The Department of Enforcement (“Enforcement”) alleges: SUMMARY 1. Between June 1, 2014 and July 31, 2017, Hicks made unsuitable recommendations to five senior customers (three of whom were widows) to purchase speculative non-traded real estate investment trusts (“REITs”) and non-traded business development companies (“BDCs”).

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. KAPIL MAHESHWARI (CRD No. 6358540), Respondent. Disciplinary Proceeding No. 2017055608101 Hearing Officer-DW HEARING PANEL DECISION December 19, 2019 Respondent Kapil Maheshwari misused confidential information obtained from his former employer about a future corporate acquisition for trading purposes, in violation of FINRA Rule 2010. For his misconduct, Maheshwari is barred from association with any FINRA member in any capacity and