Between May 2022 and August 2023, Ceros served as placement agent in three contingency offerings (the Offerings). Ceros failed to terminate the Offerings and promptly return investor funds when there were material changes to the terms of the Offerings. Therefore, Ceros willfully violated Exchange Act Rule 10b-9 and violated FINRA Rule 2010. From at least May 2022 to at least August 2023, Ceros failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs ), reasonably designed to achieve compliance with Exchange Act Rule 10b-9.

From July 2015 through June 2020, Newbridge failed to reasonably supervise recommendations for margin use by two representatives in five customer accounts. As a result, Newbridge violated FINRA Rules 3110 and 2010.