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V. Impeding Regulatory Investigations [Version up to May. 1, 2018]

•   Confidentiality Agreements—Settling With Customer in Exchange for Customer Agreement Not to Cooperate With Regulatory Authorities
•   Failure to Respond, Failure to Respond Truthfully or in a Timely Manner, or Providing a Partial but Incomplete Response to Requests Made Pursuant to FINRA Rule 8210
•   Settling Customer Complaints Away From the Firm

Confidentiality Agreements—Settling With Customer in

IV. Financial and Operational Practices [Version up to May. 1, 2018]

•   Customer Confirmations—Failure to Comply With Rule Requirements
•   Customer Protection Rule—Failure to Comply With Rule Requirements
•   Net Capital Violations
•   Recordkeeping Violations
•   Regulation T and Margin Requirements—Violations of Regulation T and/or FINRA Margin Requirements

Customer Confirmations—Failure to Comply With Rule Requirements

III. Distributions of Securities [Version up to May. 1, 2018]

•   Corporate Financing Rule—Failure to Comply With Rule Requirements
•   Engaging in Prohibited Municipal Securities Business
•   Escrow Violations—Prohibited Representations in Contingency Offerings; Transmission or Maintenance of Customer Funds in Underwritings
•   Restrictions on the Purchase and Sale of Initial Equity Public Offerings Violations
•   Unregistered Securities—Sales of

Corpor

I. Activity Away From Associated Person's Member Firm [Version up to May. 1, 2018]

•   Outside Business Activities—Failure to Comply With Rule Requirements
•   Selling Away (Private Securities Transactions)
•   Transactions for or by Associated Persons—Failure to Comply With Rule Requirements

Outside Business Activities—Failure to Comply With Rule Requirements

FINRA Rules 2010 and 3270

Technical Matters [Version up to May. 1, 2018]

Calculation of days of suspension. As was the case in prior versions of the FINRA Sanction Guidelines, recommendations for the imposition of suspensions contained herein distinguish between suspensions for 30 or fewer days and 31 or more days. In these guidelines, the NAC recommends that a suspension of 30 or fewer days be measured in business days, while a suspension of 31 or more days be measured in calendar days.

Applicability [Version up to May. 1, 2018]

These guidelines supersede prior editions of the FINRA Sanction Guidelines, whether published in a booklet or discussed in FINRA Regulatory Notices (formerly NASD Notices to Members). These guidelines are effective as of the date of publication, and apply to all disciplinary matters, including pending matters. FINRA may, from time to time, amend these guidelines and announce the amendments in a Regulatory Notice or post the changes on FINRA's website (www.finra.org).