FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017053705201 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Samuel K. Van Allen, Respondent CRD No. 4464706 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, I, Samuel K. Van Allen (“Van Allen” or “Respondent”), submit 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 LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059546401 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Brenda M. Kochel, Respondent Former Investment Company and Variable Contracts Products Representative CRD No. 5212755 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent Brenda M. Kochel ("Respondent" or "Kochel") submits this Letter of Acceptance, Waiver and

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. DANIEL G. MAUGHAN CRD No. 2561363, Respondent. Disciplinary Proceeding No. 2017054755206 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. Respondent Daniel G. Maughan, while associated with Financial West Group ("Financial West" or the "Firm"), a FINRA-regulated broker-dealer, churned and excessively

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018060898601 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Eric Savell, Respondent Former Registered Representative CRD No. 4182368 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I submit 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 LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017054847101 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: David Wilson Fleming, Respondent Former Registered Representative CRD No. 1021968 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I submit 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. Robert Juan Escobio (CRD No. 703813), Respondent. DISCIPLINARY PROCEEDING NO. 2018059545201 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. From March 2019 to the present, Respondent Robert Juan Escobio has repeatedly failed to provide information and documents requested by FINRA Staff pursuant to FINRA Rule 9210 in an investigation involving whether Escobio

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2013037572601 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Lime Brokerage LLC, Respondent Broker-Dealer CRD No. 104369 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Lime Brokerage LLC ("Lime" or the "Firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017056440501 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Western International Securities, Inc., Respondent CRD No. 39262 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Western International Securities, Inc. ("Western" or the "Firm") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2016049977201 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Park Avenue Securities LLC, Respondent CRD No. 46173 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Park Avenue Securities LLC ("PAS" or the "Firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule