FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059532901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Stewart I. Schram (Respondent) General Securities Representative CRD No. 1711571 Pursuant to FINRA Rule 9216, Respondent Stewart I. Schram 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 ENFORECEMENT, Complainant, v. RICKY ALAN MANTEI, (CRD No. 1098981), Respondent. Disciplinary Proceeding No. 2015045257501 Hearing Officer—DRS EXTENDED HEARING PANEL DECISION February 18, 2021 Respondent violated his firm’s prearranged trading prohibition and circumvented its cross trade procedures by directing prearranged trading with intermediaries in order to facilitate and disguise cross trades. For this misconduct,