2019061507001 Luke C. Nelson CRD 6217103 AWC va (2020-1599959128446).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019061507001 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Luke C. Nelson, Respondent Former Registered Representative CRD No. 6217103 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Luke C. Nelson submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020065385101 Andrew M. Arthur CRD 1864083 AWC va (2020-1599959128594).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2020065385101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Andrew M. Arthur, Respondent General Securities Representative CRD No. 1864083 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Andrew M. Arthur submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2020066424801 Michael Erwin CRD 6774571 AWC sl (2020-1599959128402).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2020066424801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Michael Erwin, Respondent General Securities Representative CRD No. 6774571 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Michael Erwin 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 on the

Regulatory Notice 20-29

Summary

FINRA requests comment on the practice of internalizing customer trades in the corporate bond market after obtaining auction responses, commonly known as “pennying.” In particular, pennying involves a dealer, after receiving a customer order, initiating a bid or offer wanted auction process on behalf of a customer, reviewing the auction responses, and then executing the customer order itself at a price that either matches or slightly improves the best priced auction response.

2017055128201 BGC Financial, L.P. CRD 19801 AWC sl (2020-1599959128680).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017055128201 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: BGC Financial, L.P., Respondent Member Firm CRD No. 19801 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent BGC Financial, L.P. (“BGC Financial” or the “firm”) submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2019063061701 Richard Denecker CRD 1065784 AWC sl (2020-1599959128647).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019063061701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Richard Denecker, Respondent General Securities Representative CRD No. 1065784 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Richard Denecker 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 on the

2019064174601 Forouzan Pooladi CRD 6642157 AWC sl (2020-1599959128523).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019064174601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Forouzan Pooladi, Respondent Former Registered Representative CRD No. 6642157 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent Forouzan Pooladi submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

2019063061601 Wiliam Daly CRD 2771735 AWC sl (2020-1599959128701).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019063061601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: William Daly, Respondent General Securities Representative CRD No. 2771735 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent William Daly 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 on the
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