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2019064323202 Michael Keith Napier CRD 4811092 AWC jlg (2021-1618186805423).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019064323202 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Michael Keith Napier (Respondent) General Securities Representative and Investment Company and Variable Contracts Products Representative CRD No. 4811092 Pursuant to FINRA Rule 9216, Respondent Michael Keith Napier submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

9285. Interim Orders and Mandatory Heightened Supervision While on Appeal or on Discretionary Review

(a) Conditions and Restrictions
(1) Motion for Conditions or Restrictions
Unless otherwise ordered by a Hearing Officer, within 10 days after service of a notice of appeal from, or the notice of a call for review of, a decision issued pursuant to Rule 9268 or Rule 9269 in which the Hearing Panel or, if applicable, the Extended Hearing Panel or the Hearing Officer finds that a Respondent violated a statute or rule provision, the Department of Enforcement m

IM-1011-3. Business Expansions and Persons with Specified Risk Events

The safe harbor for business expansions in IM-1011-1 is not available to any member that is seeking to add a natural person who has, in the prior five years, one or more final criminal matters or two or more specified risk events and seeks to become an owner, control person, principal, or registered person of the member; in such circumstances, if the member is not otherwise required to file a Form CMA in accordance with Rule 1017, the member must comply with the requirements of Rule 1017(a)(7).