FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018058344301 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Axos Clearing LLC,1 Respondent Member Firm BD No. 117176 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Axos Clearing LLC ("Axos Clearing" or the "Firm") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018058932001 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Zvi Ben-Zvi, Respondent CRD No. 2994766 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, Zvi Ben-Zvi ("Ben-Zvi" or "Respondent") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018057366101 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Michael P. Spolar, Respondent General Securities Representative CRD No. 2192992 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, I, Michael P. Spolar (“Spolar” or “Respondent”) submit this Letter of Acceptance, Waiver and Consent (“AWC”) for the purpose of proposing a settlement of the alleged rule

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2016051985602 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Michael Thomas Lee, Respondent General Securities Representative CRD No. 4502893 Pursuant to FINRA Rule 9216 of FINRA’s Code of Procedure, I, Michael Thomas Lee (“Lee” or “Respondent”), submit this Letter of Acceptance, Waiver and Consent (“AWC”) for the purpose of proposing a settlement of the alleged rule

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Richard O. White Charlotte, North Carolina, Respondent. DECISION Complaint No. 2015045254501 Dated: July 26, 2019 Respondent structured cash deposits to avoid federal reporting requirements. Held, findings affirmed and sanction modified. Appearances For the Complainant: Leo F. Orenstein, Esq., Joseph E. Strauss, Esq., Savvas A. Foukas, Esq., Tiffany A. Buxton, Esq.,

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2019061459801 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Robert F. Montes, Respondent Registered Representative CRD No. 835488 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, Robert F. Montes ("Montes" or "Respondent") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059146801 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Michael David Garris, Respondent Former General Securities Representative CRD No. 1540384 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, Michael David Garris ("Respondent") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018057298401 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Charles L. Laubach, Respondent CRD No. 1097453 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, I, Charles L. Laubach ("Laubach" or "Respondent") submit this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2017055302801 TO: Department of Enforcement Financial Industry Regulatory Authority (“FINRA”) RE: Adriana Marcela Agha, Respondent Former Registered Representative CRD No. 4827296 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. 2014038990602 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: Crown Capital Securities, L.P., Respondent Member Firm CRD No. 6312 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a settlement of the alleged rule violations