From July 2019 to the present, Odeon failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with applicable securities laws and regulations prohibiting prearranged trading, a form of manipulative trading, in violation of FINRA Rules 3110 and 2010.

Between July 2020 and May 2024, D. Boral Capital conducted a securities business on 96 days while failing to maintain the firm’s minimum required net capital. As a result, the firm violated Securities Exchange Act Section 15(c)(3), Exchange Act Rule 15c3-1, and FINRA Rules 4110(b)(1) and 2010. From July 2020 through May 2024, the firm failed to establish and maintain written supervisory procedures reasonably designed to achieve compliance with net capital requirements.