Between September 2021 and June 2022, Benchmark failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to prevent prohibited trade-throughs of protected quotations in National Market System securities. Benchmark additionally failed to take reasonable steps to establish that the intermarket sweep orders (ISOs) it routed to certain market centers met the requirements for an ISO. As a result, Benchmark violated Rules 611(a) and (c) of Regulation NMS of the Securities Exchange Act of 1934 and FINRA Rules 3110 and 2010.

Between March 2021 and December 2022, Girasole forged the electronic signatures of five customers and three registered representatives on a total of six life insurance applications, each of which the insurance provider cancelled before the assessment of premiums. Therefore, Girasole violated FINRA Rule 2010. For this conduct, Girasole is suspended for two months and is fined $5,000.