From September through November 2021, Respondent Jason Michael Poschinger, while registered with FINRA through an association with FINRA member firm OneAmerica Securities, Inc. (OAS) (BD No. 4173) downloaded from the firm’s computer systems confidential information that constituted nonpublic personal customer information and sent the customer data to two non-firm email addresses that he controlled and provided the information to another FINRA member firm (Firm A) for his own benefit.

It has been determined that the Offer be accepted and that findings be made as follows: On two occasions, Respondent Christopher J. Christensen failed to provide documents and information FINRA requested pursuant to FINRA Rule 8210 as part of FINRA’s examination of Christensen’s outside business activities and private securities transactions. As a result, Christensen violated FINRA Rules 8210 and 2010. Christensen also failed to appear for testimony FINRA requested on two occasions pursuant to FINRA Rule 8210 as part of FINRA’s examination.

Between January 2022 and September 2022, USCA conducted a securities business on 35 days while failing to maintain its minimum required net capital, in violation of Section 15(c)(3) of the Securities Exchange Act of 1934, Exchange Act Rule 15c3-1, and FINRA Rules 4110 and 2010. From December 2021 through July 2022, USCA failed to maintain accurate financial books and records and filed with FINRA eight inaccurate Financial Operational Combined Uniform Single (FOCUS) reports, in violation of Exchange Act § 17(a), Exchange Act Rules 17a-3 and 17a-5, and FINRA Rules 4511 and 2010. From at least Ja