Between January 2021 and June 2024, Sullivan exercised discretion without prior written authorization in connection with 581 transactions in accounts held by two customers. As a result, Sullivan violated FINRA Rules 3260(b) and 2010. During the same period, Sullivan mismarked the 581 discretionary trades as unsolicited. By causing his firm to maintain inaccurate books and records, Sullivan violated FINRA Rules 4511 and 2010. For these violations, Sullivan is suspended in all capacities for three months and fined $10,000.

SECURITIES AND EXCHANGE COMMISSION Washington, D.C. SECURITIES EXCHANGE ACT OF 1934 Release No. 106028 / August 3, 2026 Admin. Proc. File No.