It has been determined that the Offer be accepted and that findings be made as follows: For more than four years, Spartan Capital Securities, LLC, defrauded customers by engaging in widespread churning, generating millions in revenue, and causing customers millions in harm. Spartan’s business model depended on this misconduct – approximately two-thirds of the firm’s trading revenue and one-third of its overall revenue, more than $46 million in total, was generated from more than 1,200 accounts with a cost-to-equity ratio greater than 20% from January 2018 to April 2022.

The Department of Enforcement alleges: Respondent Joel A. Benanti failed to provide information and documents requested pursuant to FINRA Rule 8210 as part of FINRA’s investigation into whether Benanti participated in undisclosed outside business activities and private securities transactions away from his employer member firm. As a result, Benanti violated FINRA Rules 8210 and 2010...