Between September 2020 and December 2023, Colliers violated MSRB Rule G-14 by failing to use the required special condition indicator for transactions in new issue municipal securities that the firm reported to the MSRB's Real-Time Transaction Reporting System (RTRS).

From January 2020 to September 2022, Pronovost engaged in an outside business activity by acting as a trustee to the estate of a deceased Cambridge customer without providing prior written notice to Cambridge or Osaic. As a result, Pronovost violated FINRA Rules 3270 and 2010. For this violation, Pronovost is suspended for two months and fined $7,500.

Between July 2020 and February 2021, while associated with MML, Respondent forwarded approximately $12,000 for the benefit of people he did not know to a third party located overseas, despite red flags that the funds may have been related to illegal activity. Therefore. Respondent violated FINRA Rule 2010, is suspended for nine months and fined $10,000.

From at least June 2021 to the present, PNCI failed to establish and maintain a reasonably designed supervisory system, including written supervisory procedures (WSPs), for the surveillance of rates of deferred variable annuity (VA) exchanges. The firm’s supervisory system did not require the firm to determine if its associated persons had rates of effecting VA exchanges that raised for review whether such rates evidenced conduct inconsistent with FINRA rules or the federal securities laws as required by FINRA Rule 2330(d), and did not provide guidance as to how to make that determination.