Ben Feldmeyer Comment On Regulatory Notice 25-05

May 13, 2025

Ms. Jennifer Piorko Mitchell Office of the Corporate Secretary FINRA

1735 K Street

Washington, DC 20006

Re: Request for Commenton Regulatory Notice25-05

Dear Ms. Mitchell,

I am an owner of a Registered Investment Advisory firm and a registered representative of an unaffiliated FINRA member firm. I appreciate the opportunity to comment on the newly proposed Rule 3290 as set forth in FINRA Regulatory Notice 25-05.

2023078904101 Kyle J. Charters CRD 6288496 AWC vr (2025-1749687609128).pdf

In 2022, while associated with ICS, Charters participated in a private securities transaction involving the sale of a limited partnership interest in an offering sponsored by a private equity firm that Charters was hoping to join. Charters participated in the private securities transaction without any notice to ICS. By doing so, Charters violated FINRA Rules 3280 and 2010 and is suspended for six months from associating with any FINRA member and fined $10,000.

2024081111101 Judah Spinner CRD 7039921 AWC vr (2025-1749687609144).pdf

Between June and December 2021 and January 2022 and January 2024, while associated with PFS Investments, Spinner participated in 41 private securities transactions without providing written notice to the firm, in violation of FINRA Rules 3280 and 2010. For these violations, he is suspended for 12 months from associating with any FINRA member in all capacities and fined $10,000.
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