Between May 2017 and February 2023, Kelly recommended to four retail customers a series of trades that were excessive, quantitatively unsuitable, and not in the customers’ best interests. As a result, Kelly willfully violated the Best Interest Obligation under Rule 15l-l(a)(l) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and 2010 in the case of one customer and violated FINRA Rules 2111 and 2010 in the case of three customers. For these violations, Kelly is suspended for nine months in all capacities, fined $10,000, and ordered to pay restitution of $69,830 plus interest.

From February 2017 through April 2020 Burks recommended that three customer invest an unsuitably high concentration of their accounts in alternative investments which were illiquid or had limited liquidity and subjected the customers to a substantial risk of loss. As a result, Burks violated FINRA Rules 2111 and 2010. For these violations, be is suspended for four months and fined $10,000...

Between January 2019 and February 2023, Herrera recommended to two retail customers a series of trades that were excessive, unsuitable, and not in the customers' best interests. As a result, Herrera willfully violated the Best Interest Obligation under Rule 15l-1 (a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Herrera is suspended for six months in all capacities, fined $5,000, and ordered to pay restitution of $158,500 plus interest...