Between April and September 2022, CIM sold to one investor a private placement offering for which no exemption from registration was available and, therefore, constituted an unregistered distribution of securities in contravention of Section 5 of the Securities Act of 1933, and, thereby, a violation of FINRA Rule 2010. During the same period, CIM failed to reasonably respond to red flags concerning the issuer of that same offering, in violation of FINRA Rules 3110 and 2010.