From at least January 2018 to February 2025, Cambridge failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to surveil rates of deferred variable annuity exchanges. As a result, the firm failed to detect 22 “inappropriate exchanges,” as defined in FINRA Rule 2330(d), by a former registered representative that caused 14 customers to incur $129,938.79 in unnecessary surrender fees. Accordingly, Cambridge violated FINRA Rules 3110, 2330(d), and 2010.

On 17 days between August 2021 and May 2022, Chapin Davis conducted a securities business while failing to maintain the required minimum net capital and failed to notify the SEC or FINRA of those deficiencies.

Cooke refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, Cooke violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.