Between October 2021 and July 2022, Network 1 failed to reasonably supervise a sales representative's activity relating to a private placement in violation of FINRA Rules 3110 and 2010. In April 2022, Network 1 distributed offering materials for the private placement that contained erroneous and/or misleading information in violation of FINRA Rules 2210 and 2010. For these violations, Network 1 is censured, fined $50,000, and agrees to remediate the issues identified in this AWC...

The Department of Enforcement alleges: 1. In November and December 2024, Respondent Michael Cheng Ning, in his capacity as custodian of records for former member firm Arque Capital, Ltd., failed to respond to requests for documents and information that FINRA made pursuant to FINRA Rules 4570(b) and 8210 as part of FINRA’s investigation into whether certain securities recommendations by the firm’s registered representatives to customers of two former Arque Capital registered representatives were in the best interests of their customers.

From June 2019 through June 2022, XP violated FINRA Rules 5210 and 2010 by overstating its advertised trade volume on Bloomberg, a private, subscription-based provider of market data, in approximately 3,300 instances by approximately 446 million shares. From at least June 2019 through December 2023, XP violated FINRA Rules 3110 and 2010 by not establishing and maintaining a supervisory system, including written supervisory procedures (WSPs), reasonably designed to achieve compliance with FINRA Rule 5210. For these violations, XP is censured and fined $185,000.