FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2020068888501 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Doli Kumar (Respondent) Former Investment Company and Variable Contracts Products Representative CRD No. 6586313 Pursuant to FINRA Rule 9216, Respondent Doli Kumar submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant, v. Spartan Capital Securities, LLC BD No. 146251 John D. Lowry CRD No. 4336146 Kim M. Monchik CRD No. 2528972, Respondents. Disciplinary Proceeding No. 2019061528001 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. From January 1, 2015 to December 31, 2020 (the “relevant period”), Spartan Capital Securities, LLC failed to file, or to timely file, 223 amendments to the Uniform Applications for