FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018058202901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: James Richards, Respondent Registered Representative CRD No. 3120249 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent James Richards ("Richards" or "Respondent") 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. BRYCE PATRICK JENNEY (CRD No. 6207379), Respondent. Disciplinary Proceeding No. 2018060216701 Hearing Officer-DW AMENDED DEFAULT DECISION April 9, 2020 For failing to produce documents and twice failing to appear and provide on-the-record testimony during an investigation as required by FINRA Rule 8210, Respondent is barred from associating with any FINRA member in any capacity.

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018056386601 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Chapin, Davis, Respondent Member Firm CRD No. 28116 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Chapin, Davis ("Chapin, Davis" 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.