Between September 2019 and January 2020, Noble failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with provisions of the federal securities laws related to the general solicitation of private placement offerings. Additionally, Noble failed to reasonably supervise a registered representative who, in connection with two private offerings, cold-called more than 40 prospective investors who did not have substantive relationships with the firm prior to its participation in the offerings.

Respondent Meredith Webber failed to respond to requests for documents and information that FINRA made pursuant to FINRA Rule 8210 and failed to provide on-the-record (OTR) testimony that FINRA requested pursuant to FINRA Rule 8210 as part of FINRA’s investigation into whether Webber misappropriated funds from two elderly customers. As a result, Webber violated FINRA Rules 8210 and 2010. It is ordered that Respondent be barred from associating in any capacity with any FINRA member.