From November 2023 to December 2023, Webster recommended that 19 of his customers, at least 13 of whom were seniors, implement a short-term strategy that involved buying stocks in commission-based brokerage accounts rather than in the customers’ existing fee-based advisory accounts at a lower comparative cost. Webster did not have a reasonable basis to believe that buying the stocks at a greater cost in the brokerage accounts was in the customers’ best interests.

From November 2022 through April 2024, Stirlingshire violated Rule 15l-1 of the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rules 3110 and 2010, by failing to establish, maintain, and enforce a reasonable supervisory system, including written supervisory procedures (WSPs), concerning recommendations of inverse or leveraged exchange traded funds (NT-ETFs).

Between October 2019 and July 2021, Virtu violated Rule 611(c) of Regulation National Market System (NMS) of the Securities Exchange Act of 1934 and FINRA Rule 2010 by failing to take reasonable steps to establish that 88,500 intermarket sweep orders (ISOs) routed by the firm to certain market centers met the requirements for ISOs. For these violations, Virtu is censured and fined $6,930.

The Department of Enforcement alleges: SUMMARY 1. Respondent Tory A. Duggins, failed to provide on-the-record (“OTR”) testimony requested pursuant to FINRA Rule 8210 as a part of FINRA’s investigation into whether Duggins churned and excessively traded customer accounts. As a result, Duggins violated FINRA Rules 8210 and 2010.

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICE Disciplinary Proceeding No. 2021071987902 Department of Enforcement, Complainant, v. Sutter Securities, Inc., CRD No. 30770 and Keith Charles Moore, CRD No. 5191450 Respondents. COMPLAINT The Department of Enforcement alleges: SUMMARY Between March 2020 and July 2021 (the relevant period), Respondent Sutter Securities Inc. (Sutter), acting through a former Sutter registered representative (Representative1), recommended and effected 2,217 trades in two accounts belonging to a retired, 89-year-old customer (Customer 1).