From June 30, 2020, to May 10, 2024, when recommending that his retail customers sell Class A mutual funds and then purchase new Class A mutual funds that imposed a new front-end sales charge, Brode failed to consider whether his customers could have achieved their objectives by exchanging into a new mutual fund within the same fund family, which would not have required the customers to pay a new front-end sales charge. As a result, Brode willfully violated the Care Obligation of Rule 15/-1 of the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rule 2010.