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2018060409301 Barry John Hartwyk CRD 1527583 AWC jlg (2020-1595204367647).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018060409301 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Barry John Hartwyk, Respondent General Securities Representative CRD No. 1527583 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Barry John Hartwyk submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted

5110. Corporate Financing Rule — Underwriting Terms and Arrangements

(a) Requirements for Public Offerings
(1) General
(A) No member or person associated with a member shall participate in a public offering in which the terms and conditions relating thereto, including the aggregate amount of underwriting compensation, are unfair or unreasonable pursuant to this Rule or inconsistent with any By-Law or any rule or regulation of FINRA.
(B) Any member acting as a managing underwriter or in a similar capacity must noti

2111. Suitability

(a) A member or an associated person must have a reasonable basis to believe that a recommended transaction or investment strategy involving a security or securities is suitable for the customer, based on the information obtained through the reasonable diligence of the member or associated person to ascertain the customer's investment profile.