FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019060783602 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Byron Pat Treat (Respondent) General Securities Principal CRD No. 1466393 Pursuant to FINRA Rule 9216, Respondent Byron Pat Treat 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, Megurditch Patatian CRD No. 4047060, Respondent. Disciplinary Proceeding No. 2018057235801 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. From 2013 to 2017, while associated with Western International Securities, Inc. (Western), Respondent Megurditch Patatian made 81 recommendations to 59 customers to purchase non-traded real estate investment trusts (REITs). All of Patatian's