Conversion or Improper Use of Funds or Securities

FINRA Rules 2010 and 2150¹, and NASD Rule 2330 and IM-2330

Confidentiality Agreements—Settling With Customer in

Customer Confirmations—Failure to Comply With Rule Requirements

Corpor

Arbitration Award—Failure to Honor or Failure to Honor in a Timely Manner

FINRA Rules 2010 and 10330¹

Outside Business Activities—Failure to Comply With Rule Requirements

FINRA Rules 2010 and 3270

Calculation of days of suspension. As was the case in prior versions of the FINRA Sanction Guidelines, recommendations for the imposition of suspensions contained herein distinguish between suspensions for 30 or fewer days and 31 or more days. In these guidelines, the NAC recommends that a suspension of 30 or fewer days be measured in business days, while a suspension of 31 or more days be measured in calendar days.

These guidelines supersede prior editions of the FINRA Sanction Guidelines, whether published in a booklet or discussed in FINRA Regulatory Notices (formerly NASD Notices to Members). These guidelines are effective as of the date of publication, and apply to all disciplinary matters, including pending matters. FINRA may, from time to time, amend these guidelines and announce the amendments in a Regulatory Notice or post the changes on FINRA's website (www.finra.org).

The following list of factors should be considered in conjunction with the imposition of sanctions with respect to all violations. Individual guidelines may list additional violation-specific factors.