Between January 2021 and December 2025, Brentwood failed to establish and implement an anti-money laundering (AML) compliance program reasonably designed to identify and verify the identities of the beneficial owners of its legal entity customers, in violation of FINRARules 3310(b) and 2010. Between January 2018 and January 2024, Brentwood failed to establish and implement a written AML compliance program that provided for annual (on a calendar-year basis) independent AML testing, and the firm conducted no independent AML testing between 2018 and 2023, in violation of FINRA Rules 3310(c) and 2

Joyce refused to provide information and documents requested pursuant to FINRA Rule 8210. As a result, Joyce violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

From January 2018 to July 2022, Wells Fargo failed to report 837,805 fractional share trades to the FINRA/Nasdaq Trade Reporting Facility (FNTRF) or the Over-the-Counter Reporting Facility (ORF). Additionally, from January 2018 to October 2023, the firm failed to report approximately 46,000 error correction trades to the FNTRF or ORF. Therefore, Wells Fargo violated FINRA Rules 6380A(b), 6622(b), and 2010.