24-01516(2).pdf
Amended
Robert Cruz Comment On Regulatory Notice 25-07
E.1. The phrase business as such under Exchange Act Rule 17a-4(b)(4) is not defined.34 What questions, concerns or challenges, if any, does this raise with respect to ensuring compliance with the recordkeeping requirements? Are there categories of records that are especially costly or difficult to capture or retain, and which may provide no appreciable regulatory benefit? <EA1: Ambiguity of the rule has nothing to do with the degree of difficulty to capture and retain specific types of records.
2023077646901 Manuel F. Melendez CRD 4648278 AWC lp (2025-1747354798005).pdf
Between October 2018 and February 2021, while registered through UBS, Melendez borrowed $738,000 from two firm customers through four separate loans without providing prior written notice to or obtaining written approval from UBS, in violation of FINRA Rules 3240 and 2010. Melendez used thousands of dollars from these loans to pay expenses unrelated to the loans’ purposes, in violation of FINRA Rules 2150(a) and 2010.
2021069276401 Sonenshine & Company LLC CRD 104357 AWC lp (2025-1747354798052).pdf
From July 2017 to the present, Sonenshine violated FINRA Rules 3310(b) and 2010 by failing to establish and implement policies, procedures, and internal controls reasonably designed to achieve compliance with the Bank Secrecy Act (BSA) and implementing regulation 31 C.F.R. § 1010.520, which required the firm to search its records in response to Financial Crimes Enforcement Network (FinCEN) requests.
23-00502(3).pdf
Motion to Vacate