Between December 2022 and May 2025, Su owned half of a company (Company A) that provided consulting services to public and private companies seeking to increase investor interest in their companies. Separately, Su also individually entered into a consulting contract to provide similar consulting services. However, Su never disclosed these outside business activities to Univest. Su and Company A received compensation for their consulting work in the form of restricted shares that were deposited in brokerage accounts that Su did not disclose to Univest.

From October 2010 through September 2024, JPMS failed to establish procedures to assure that certain customers received margin account disclosures required by Rule 10b- 16(a)(2) of the Securities Exchange Act of 1934 (Exchange Act) on account statements. As a result, during the period of October 2010 through February 2024, the firm failed to provide certain information in its margin account disclosures required by Exchange Act Rule 10b-16(a)(2), including the annual rates of interest charged, on 56,254 account statements corresponding to 4,463 customer accounts.