FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018060843801 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Thomas Walter Molteni, Respondent Investment Company Products/Variable Contracts Representative CRD No. 1022911 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, Respondent, Thomas Walter Molteni (“Molteni” 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.

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDIUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. David O. Braeger Milwaukee, WI, Respondent. DECISION Complaint No. 2015045456401 Dated: December 16, 2019 Registered representative misused and converted customer funds and made material misrepresentations and omissions to customers. Held, findings and sanctions affirmed. Appearances For the Complainant: Leo F. Orenstein, Esq., Suzanne H. Bertolett, Esq., Department of Enforcement,

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019061185701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Robert P. Allen, Respondent Former Investment Company and Variable Contracts Products Representative CRD No. 6267678 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Robert P. Allen submits this Letter of Acceptance, Waiver and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.