FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. SAM JAKOBS (CRD No. 6623905), Respondent. Disciplinary Proceeding No. 2023077022402 Hearing Officer–LOM DEFAULT DECISION March 20, 2025 Respondent failed to produce information and documents he was required to produce pursuant to FINRA Rule 8210. For violating FINRA Rules 8210 and 2010, he is barred from associating with any FINRA member in any capacity.

Between January 2020 and March 2021, Conn exercised discretion without prior written authorization in connection with 465 transactions in 12 accounts held by five customers. As a result, Conn violated FINRA Rules 3260(b) and 2010. In addition, from August 2019 through March 2020, Conn provided $120,000 in monetary gifts to one of those customers in circumvention of firm policy. As a result, Conn violated FINRA Rule 2010. For these violations, Conn is suspended for three months in all capacities and fined $15,000.

From January 2022 through June 2024, Financial Northeastern violated FINRA Rules 6730(a) and 2010 by failing to timely report to the Trade Reporting and Compliance Engine (TRACE) approximately 1,000 transactions in TRACE-eligible corporate debt securities. For these violations, Financial Northeastern is censured and fined $60,000.

Between July 2020 and December 2023, Liberty's supervisory system, including its written procedures, was not reasonably designed to achieve compliance with the Care Obligation of Rule 151-1 of the Securities Exchange Act of 1934 (Reg BI) with respect to its registered representatives' recommendations of non-traditional and volatility-linked exchange traded products (non-traditional ETPs). As a result, the firm failed to comply with Reg BI's Compliance Obligation and therefore violated Exchange Act Rule 15l-1(a)(1), and also violated FINRA Rules 3110 and 2010.