The Department of Enforcement alleges: 1. Between February 2022 and January 2023, while registered with FINRA through an association with Morgan Stanley, Respondent Kirk J. Crossen borrowed a total of $400,000 through three loans from a customer, Trust A. Morgan Stanley’s written supervisory procedures (WSPs) did not allow Crossen to borrow from Trust A because neither Trust A nor its beneficial owner, Individual A, was an immediate family member. At the time of the loans, Individual A was 84 years old and suffering from the onset of dementia. 2.