From April 2022 through May 2024, Rozof placed over 250 discretionary trades in the brokerage accounts of two Harley Capital customers without the written authorization required by FINRA Rule 3260(b). From March 2022 through June 2024, Rozof also used his personal cell phone to exchange business-related text messages with those two and other customers, preventing the firm from preserving those messages, in violation of FINRA Rule 4511. For these violations, Rozof is suspended for 45-calendar days in all capacities and fined $10,000.

FINRA’s Trade Reporting and Compliance Engine (TRACE) facilitates the mandatory reporting of certain securities transactions and provides increased price transparency to market participants and investors. From August 2022 through July 2024, Navian failed to accurately report, failed to report, or failed to timely report to TRACE 2,058 transactions in TRACE-eligible corporate debt securities, in violation of FINRA Rules 6730 and 2010. The firm also failed to reasonably supervise its TRACE reporting, in violation of FINRA Rules 3110 and 2010.

From January 1, 2018, through December 30, 2021, JPMS’s supervisory system, including its written supervisory procedures (WSPs), was not reasonably designed to achieve compliance with applicable preliminary initial public offering (IPO) prospectus delivery requirements for IPO allocations to the firm’s institutional customers, in violation of FINRA Rules 3110(a) and (b) and 2010. For these reasons, JPMS is censured and fined $150,000.

Uyeda refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210 in connection with a FINRA investigation into whether Uyeda borrowed money from his customers. As a result, Uyeda violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

In March 2024, Gazzo shared approximately $14,000 in commissions generated from securities transactions with an unregistered entity. As a result, Gazzo violated FINRA Rules 2040 and 2010. For these violations, Gazzo is suspended in all capacities for two months and fined $5,000.

From April 2020 to April 2025, T3 failed to comply with its obligation to publish quarterly reports concerning the firm’s handling of customer orders in National Market System (NMS) securities. T3 failed to publish any such reports from April 2020 to July 2021. Thereafter, from July 2021 to April 2025, the firm published quarterly reports that contained none, or very little, of the information that the firm was required to disclose. As a result, the firm violated Rule 606(a) of Regulation NMS under the Securities Exchange Act of 1934 and FINRA Rule 2010.

Between April 2020 and April 2022, Molinos recommended to one retail customer a series of trades that were excessive, unsuitable, and not in the customer’s best interest. As a result, Molinos willfully violated the Best Interest Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Molinos is suspended for three months in all capacities.

When determining whether to file Suspicious Activity Reports (SARs), USBI incorrectly used a $25,000 monetary threshold applicable to banks rather than the $5,000 threshold applicable to broker-dealers and, as a result, did not timely file 42 SARs between April 2020 and August 2023. USBI failed to establish and implement policies and procedures reasonably designed to detect and cause the reporting of suspicious transactions in violation of FINRA Rules 3310(a) and 2010. The firm is censured and fined $500,000.