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.