FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant v. Michael Venturino (CRD No. 5872439), Respondent. Disciplinary Proceeding No. 2021070337501 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. From July 2014 to June 2017 (the “Relevant Period”), while associated with FINRA member Aegis Capital Corp. (“Aegis” or the “firm”), Michael Venturino churned and excessively traded 12 accounts of 11 different firm customers. 2. During this period, Venturino exercised de facto control over each of the 12 accounts.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WANER, AND CONSENT NO. 2021072685301 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Michael Scott Desando (Respondent) General Securities Representative CRD No. 1849321 Pursuant to FINRA Rule 9216, Respondent Michael Scott Desando submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.