FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE,. WAIVER, AND CONSENT NO .. 2021069393901 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Financial Security Management, Incorporated (Respondent) Member Firm CRD No. 43000 Pursuant to FINRA Rule 9216, Respondent Financial Security Management, Incorporated (FSM) submits 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 Disciplinary Proceeding No. 2019063152202 Department of Enforcement, Complainant, v. Sidney Lebental, CRD No. 5543658, Respondent. COMPLAINT The Department of Enforcement alleges: SUMMARY From October 2014 through February 2021 (the Relevant Period), Respondent Sidney Lebental engaged in 523 instances of “spoofing,” a type of fraudulent trading that involves the use of non–bona fide orders to induce executions of bona fide orders entered on the opposite side of the market in the same security or a correlated product.