Between April 2020 and April 2022, Molinos recommended to one retail customer a series of trades that were excessive, unsuitable, and not in the customer’s best interest. As a result, Molinos willfully violated the Best Interest Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Molinos is suspended for three months in all capacities.

When determining whether to file Suspicious Activity Reports (SARs), USBI incorrectly used a $25,000 monetary threshold applicable to banks rather than the $5,000 threshold applicable to broker-dealers and, as a result, did not timely file 42 SARs between April 2020 and August 2023. USBI failed to establish and implement policies and procedures reasonably designed to detect and cause the reporting of suspicious transactions in violation of FINRA Rules 3310(a) and 2010. The firm is censured and fined $500,000.