Between May 14, 2018 and April 2021, Calton violated MSRB Rule G-15 and FINRA Rules 2232 and 2010 by failing to disclose required mark-up and mark-down information on hundreds of retail customer confirmations. Between July 2018 and May 2022, the firm violated MSRB Rule G-14 by failing to report the correct time of trade to the MSRB's Real-Time Transaction Reporting System (RTRS) for more than 7,800 municipal securities transactions and FINRA Rules 6730 and 2010 by failing to report the correct time of execution to TRACE for more than 1,000 securities transactions.

From February 2021 through the present, AAG Capital failed to establish and maintain written policies and procedures and a supervisory system reasonably designed to comply with Securities Exchange Act of 1934 Rule 15l-1 (Regulation Best Interest or Reg BI) for recommendations to retail customers regarding registered index-linked annuities (RILAs).

Malm accepted a bequest from the estate of a customer who was not his immediate family member without having provided his firm with written notice and without his firm having given him approval to do so. As a result, Malm violated FINRA Rules 3241 and 2010 and is suspended in all capacities for seven months and fined $10,000.

From May 2016 to October 2022, MDB Capital failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to address certain conflicts of interest and to prevent the misuse of material non-public information (MNPI). Therefore, the firm violated FINRA Rules 3110 and 2010. The firm consents to a censure, a fine of $50,000, and an undertaking to remediate the issues identified in this AWC.