Jacobs refused to provide documents and information requested pursuant to FINRA Rule 8210, in violation ofFINRA Rules 8210 and 2010. For these violations, Jacobs is barred from associating with any FINRA member in all capacities.

The Department of Enforcement alleges: 1. Between February 2022 and January 2023, while registered with FINRA through an association with Morgan Stanley, Respondent Kirk J. Crossen borrowed a total of $400,000 through three loans from a customer, Trust A. Morgan Stanley’s written supervisory procedures (WSPs) did not allow Crossen to borrow from Trust A because neither Trust A nor its beneficial owner, Individual A, was an immediate family member. At the time of the loans, Individual A was 84 years old and suffering from the onset of dementia. 2.