FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059962701 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: James Hal Heafner, Respondent Investment Company and Variable Contracts Products Representative CRD No. 4837072 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, I submit this Letter of Acceptance, Waiver and Consent (“AWC”) for the purpose of proposing a settlement of the alleged rule violations described

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Robert Charles McNamara Rye, New York, Respondent. Decision Complaint No. 2016049085401 Dated: July 30, 2019 Respondent failed to disclose to his employer brokerage accounts held at another broker-dealer, improperly purchased equity initial public offering shares in an account held at that broker-dealer, and provided inaccurate

AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019061425501 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Cynthia Rice Jones, Respondent Former General Securities Representative CRD No. 706190 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Cynthia Jones 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. 2019062228501 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Michael Filipidis, Respondent Non-Registered Fingerprint individual CRD No. 6940966 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, I submit this Letter of Acceptance, Waiver and Consent (“AWC”) for the purpose of proposing a settlement of the alleged rule violations described below.

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. SECURITIES EXCHANGE ACT OF 1934 Release No. 86523 / July 31, 2019 Admin. Proc. File No. 3-18546 In the Matter of the Application of ALLEN HOLEMAN For Review of Disciplinary Action Taken by FINRA OPINION OF THE COMMISSION REGISTERED SECURITIES ASSOCIATION--REVIEW OF DISCIPLINARY PROCEEDINGS Registered principal of FINRA member firm appeals from FINRA disciplinary action finding that he did not timely updated his Form U4 to disclose tax liens,

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019062787101 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: James T. Booth, Respondent Registered Representative CRD No. 1906145 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant, v. Wilfredo Felix (CRD No. 2693672) and Primex Prime Electronic Execution, Inc. d/b/a Primex (CRD No. 29394) Respondents. Disciplinary Proceeding No. 2018058286901 Hearing Officer: COMPLAINT The Department of Enforcement ("Enforcement") alleges: I. SUMMARY 1. From January 2013 to December 2015, Wilfredo Felix--the Chief Executive Officer, Chief Financial Officer,

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018058673601 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Tina Marie Martinez, Respondent Former Investment Company and Variable Contracts Products Representative CRD No. 5012793 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, Tina Marie Martinez ("Respondent") submit 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. 2017055074302 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: David Rookasin, Respondent CRD No. 5760016 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, David Rookasin ("Rookasin" or "Respondent"), submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019062100401 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: John Hunter Tillotson, Respondent General Securities Representative CRD No. 1320717 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent John Hunter Tillotson submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule