FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. JAMES W. FLOWER (CRD No. 2817701), Respondent. Disciplinary Proceeding No. 2017052701101 Hearing Officer—LOM EXTENDED HEARING PANEL DECISION May 27, 2021 Respondent, James W. Flower, excessively traded in five customer accounts in violation of FINRA rules regarding quantitative unsuitability. Respondent’s misconduct rose to the level of churning because he traded for his own benefit, in reckless