For one partial tender offer (PTO) in 2022, Cowen violated the Securities Exchange Act of 1934 Rule 14e-4(b)(1) and FINRA Rule 2010 by over-tendering 100,000 shares in a partial tender offer of Company 1. In addition, from October 2022 through May 2024, Cowen violated FINRA Rules 3110 and 2010 by failing to have a supervisory system, including written supervisory procedures, reasonably designed to achieve compliance with Exchange Act Rule 14e-4. For these violations, Cowen is censured, fined $80,000, of which $40,000 will be paid to FINRA.