From April 2022 through May 2024, Rozof placed over 250 discretionary trades in the brokerage accounts of two Harley Capital customers without the written authorization required by FINRA Rule 3260(b). From March 2022 through June 2024, Rozof also used his personal cell phone to exchange business-related text messages with those two and other customers, preventing the firm from preserving those messages, in violation of FINRA Rule 4511. For these violations, Rozof is suspended for 45-calendar days in all capacities and fined $10,000.

FINRA’s Trade Reporting and Compliance Engine (TRACE) facilitates the mandatory reporting of certain securities transactions and provides increased price transparency to market participants and investors. From August 2022 through July 2024, Navian failed to accurately report, failed to report, or failed to timely report to TRACE 2,058 transactions in TRACE-eligible corporate debt securities, in violation of FINRA Rules 6730 and 2010. The firm also failed to reasonably supervise its TRACE reporting, in violation of FINRA Rules 3110 and 2010.

From January 1, 2018, through December 30, 2021, JPMS’s supervisory system, including its written supervisory procedures (WSPs), was not reasonably designed to achieve compliance with applicable preliminary initial public offering (IPO) prospectus delivery requirements for IPO allocations to the firm’s institutional customers, in violation of FINRA Rules 3110(a) and (b) and 2010. For these reasons, JPMS is censured and fined $150,000.

Uyeda refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210 in connection with a FINRA investigation into whether Uyeda borrowed money from his customers. As a result, Uyeda violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.