FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2016048921103 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: PHX Financial, Inc. (Respondent) Member Firm CRD No. 144403 Robert Delaplain (Respondent) General Securities Principal CRD No. 1017107 Pursuant to FINRA Rule 9216, Respondents PHX Financial, Inc. (PHX) and Robert Delaplain submit this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019064867601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Gautam Arora (Respondent) Former Investment Company and Variable Contracts Product Representative CRD No. 5443201 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Gautam Arora 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 LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018057389701 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, 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 LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019062973402 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Najib H. Khan (Respondent) Former Investment Company and Variable Contracts Products Representative CRD No. 5771774 Pursuant to FINRA Rule 9216, Respondent Khan 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. Kane H. Waller CRD No. 4537969, Respondent. Disciplinary Proceeding No. 2017055164001 Hearing Officer—MJD ORDER ACCEPTING OFFICER OF SETTLEMENT Date: December 17, 2020 INTRODUCTION Disciplinary Proceeding No. 2017055164001 was filed on December 2, 2019, by the Department of Enforcement of the Financial Industry Regulatory Authority (FINRA or Complainant). Respondent Kane H. Waller submitted an

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019064942101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Brian Radoo (Respondent) Former General Securities Representative CRD No. 2558458 Pursuant to FINRA Rule 9216, Respondent Brian Radoo 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 LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2019062350301 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Michael Anthony Tavel (Respondent) Former Investment Company and Variable Contracts Representative CRD No. 4862463 Pursuant to FINRA Rule 9216, Respondent Michael Anthony Tavel submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.