From January 2014 through March 2022, Wells Fargo failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information. When certain registered representatives departed the firm, it failed to notify insurance carriers, resulting in the former representatives maintaining access to firm customer records and information through the carriers’ portals. As a result, the firm violated Rule 30(a) of Regulation S-P of the Securities Exchange Act of 1934, FINRA Rules 3110(a), 3110(b), and 2010, and NASD Rule 3010.

Between May 2017 and March 2020, Navarro participated in private securities transactions without prior written notice to his firms. Navarro facilitated the investment of $87,500 by five firm customers, in violation of FINRA Rules 3280 and 2010. In 2019 and 2022, Navarro borrowed a total of $80,000 from two firm customers without seeking prior approval from his firm, in violation of FINRA Rules 3240 and 2010. In June 2023, Navarro initially provided a partial and misleading response to FINRA in violation of FINRA Rules 8210 and 2010.