FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2020065125701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Arque Capital, Ltd. (Respondent) Member Firm CRD No. 121192 Michael C. Ning (Respondent) Operations Professional and General Securities Principal CRD No. 1229733 Pursuant to FINRA Rule 9216, Respondents Arque Capital, Ltd. and Michael C. Ning submit this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.