From March 2019 through June 2019, Kingswood failed to reasonably supervise a former registered representative’s recommendations of illiquid alternative investments to three senior customers. Kingswood also failed to establish and maintain written procedures reasonably designed to achieve compliance with suitability requirements with respect to those alternative investments. Kingswood therefore violated FINRA Rules 3110 and 2010. For these violations, Kingswood is censured and fined $150,000.

In his capacity as the designated custodian of records for a former member firm, Michael Cheng Ning failed to respond to requests for documents and information from FINRA staff in violation of FINRA Rules 4570(b), 8210, and 2010. For this misconduct, Respondent is barred from associating with any FINRA member firm in any capacity.

Davis refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210 in connection with a FINRA investigation into whether Davis engaged in an undisclosed private securities transaction. As a result, Davis violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

Respondent is barred from associating with any FINRA member firm in any capacity for failing to respond to requests for documents and information from FINRA staff, in violation of FINRA Rules 8210 and 2010.

Respondent Christopher Cacace is fined $5,000, suspended in all supervisory capacities for 30 business days, and required to requalify as a General Securities Principal for failing to fulfill his supervisory responsibility to reasonably respond to red flags of excessive trading by four registered representatives, in violation of FINRA Rules 3110 and 2010.

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

Between July 2019 and January 2023, Flow Traders inaccurately reported over 103,000 transactions to the Trade Reporting and Compliance Engine (TRACE) without the required No Remuneration (NR) indicator, in violation of FINRA Rules 6730(d)(1) and (d)(4)(F) and 2010. During the same period, Flow Traders also failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with FINRA Rules 6730(d)(1) and (d)(4)(F), in violation of FINRA Rules 3110(a), 3110(b), and 2010.