United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT Argued September 24, 2020 Decided November 6, 2020 No. 19-1214 John M.E. Saad, Petitioner v. Securities and Exchange Commission, Respondent On Petition for Review of an Order of the Securities and Exchange Commission Sarah Levine argued the cause for petitioner. With her on the briefs was Alex Potapov. Dina B. Mishra, Senior Counsel, Securities and Exchange Commission, argued the cause for respondent. With her on the brief was John IV. Avery, Deputy Solicitor. Michael A.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017055673701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Citigroup Global Markets Inc., Respondent Member Firm CRD No. 7059 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Citigroup Global Markets Inc. (CGMI) 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. David R. Oakes CRD No. 1465154, Respondent. Disciplinary Proceeding No. 2018057755201 Hearing Officer - DDM ORDER ACCEPTING OFFER OF SETTLEMENT Date: November 9, 2020 INTRODUCTION Disciplinary Proceeding No. 2018057755201 was filed on March 11, 2020, by the