Moran, as FinOp for StartEngine, allowed the firm to conduct a securities business while failing to maintain its minimum required net capital and failed to file timely notifications of the firm 's net capital deficiencies between August 2021 and December 2021. Moran also caused the firm to inaccurately calculate its customer reserve amounts and not maintain a sufficient balance in its customer reserve account between April 8, 2022 and July 22, 2022.

Between May 2018 and August 2022, EFG violated FINRA Rules 3310(a) and 2010 by failing to establish and implement policies and procedures for its AML compliance program that could be reasonably expected to detect and cause the reporting of suspicious transactions. As a result, EFG is censured and fined $650,000.

Between September 2023 and January 2024, while he was associated with Wells Fargo, Townsend violated FINRA Rules 4511 and 2010 by sending business-related text messages on his personal cell phone, causing Wells Fargo to fail to preserve business related text messages. During the subsequent firm investigation, Townsend falsely stated to Wells Fargo that he did not send business-related text messages and deleted the messages from his cell phone in order to impede the firm's investigation, thereby violating FINRA Rule 2010.