From April 2022 through May 2024, in approximately 1,725 instances, BNY Mellon Capital Markets reported transactions to the MSRB’s Real Time Transaction Reporting System (RTRS) without the required special condition indicator for transactions in new issue municipal securities, in violation of MSRB Rule G-14. From April 2022 through at least May 2024, the firm violated MSRB Rule G-27 by failing to establish and maintain a supervisory system, including written procedures, reasonably designed to ensure compliance with the firm’s reporting obligation under MSRB Rule G-14.

Between May 2023 and May 2024, Mogol initiated through his firm brokerage account 30 electronic transfers totaling approximately $85,000 to transfer money from his personal bank account to his firm brokerage account knowing that his bank account lacked sufficient funds to cover the transfers. He used the funds credited to his brokerage account before the transfers were reversed due to insufficient funds. By virtue of this conduct, Mogol violated FINRA Rule 2010. Mogol is suspended for six months and fined $5,000.

From November 2016 through November 2023, Wells Fargo failed to timely cancel or close out 209 failed inter-dealer transactions in municipal securities totaling approximately $6.5 million and failed to timely deliver I 06 municipal securities totaling approximately $3.8 million, violating MSRB Rule G-12(h).