BEFORE THE FINANCIAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Steven E. Larson Nisswa, MN, Respondent. DECISION Complaint No. 2014039174202 Dated: September 21, 2020 Registered principal fraudulently misrepresented and omitted material facts, failed to comply fully and promptly with FINRA requests for information, backdated and provided falsified records to FINRA, and filed a misleading

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018060527701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: David Leroy Johnson, Respondent Former General Securities Representative CRD No. 3147633 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent David Leroy Johnson (Johnson 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. 2018060180102 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Neil James Buono, Respondent Former Investment Company & Variable Contracts Products Representative CRD No. 6768349 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Neil Buono (Buono) 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. 2019062789901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Roger Allan Duval, Respondent General Securities Representative CRD No. 2503718 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Roger Allan Duval submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Eric S. Smith Troy, MI, Respondent. DECISION Complaint No. 2015043646501 Dated: September 18, 2020 Respondent fraudulently misrepresented and omitted material facts in connection with the sale of securities and failed to register as a general securities representative and principal despite engaging in conduct requiring registration. Held, findings affirmed