Respondent failed to pay a $775,346 arbitration award and failed to prove that he had a bona fide inability to pay or make a meaningful payment toward the award. Respondent is therefore suspended from associating with any FINRA member in any capacity.

Respondent engaged in a pattern of unsuitable trading in mutual fund shares in violation of FINRA Rules 2111 and 2010. He facilitated the unsuitable trading by circumventing his firm’s supervision, which was unethical and violated FINRA Rule 2010. He also falsely marked mutual fund transactions as unsolicited when they were not, which caused his firm’s books and records to be inaccurate and violated FINRA Rules 4511 and 2010. For this misconduct, we bar Respondent from associating with any FINRA member firm in any capacity and order him to pay costs.

Respondent is barred from associating with any FINRA member firm in any capacity for failing to respond to requests for documents and information from FINRA staff, in violation of FINRA Rules 8210 and 2010.

Respondents Jeffrey K. Galvani and Stuart A. Jeffery failed to provide testimony requested pursuant to FINRA Rule 8210, thereby violating FINRA Rules 8210 and 2010. For this misconduct, each Respondent is barred from associating with any FINRA member firm in any capacity.