Stavis Wealth Transfer Solutions Comment On Regulatory Notice 25-05

Dear Ms. Mitchell,

I am the owner of a Registered Investment Advisory firm in Houston, Texas, with five employees and a registered representative of an unaffiliated FINRA member firm.

My position is that rule 3290 in regulatory notice 25–05 would duplicate oversight, and the inefficiency is likely to create unnecessary complexity for RAA’s, unaffiliated Broker Dealers, and most importantly, valued clients.

2021072231801 Webull Financial LLC CRD 289063 AWC vr (2025-1749342003744).pdf

From January 2019 to December 2022, Webull Financial failed to reasonably supervise and retain social media communications that promoted the firm posted by individuals with followings on social media (commonly known as "influencers''). Some of those communications included statements that were not fair and balanced or were promissory or exaggerated.

2018056490325 Nicholas J. Schiano CRD 4429212 AWC vr (2025-1749342003685).pdf

Between September 2017 and March 2022, Schiano recommended to two retail customers a series of trades that were excessive. As a result, Schiano willfully violated the Best Interest Obligation under Rule 15/-l(a)(l) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Schiano is suspended for six months in all capacities, fined $5,000, and ordered to pay partial restitution of $55,770 plus interest...

2018056490329 Joseph L. Tranchina CRD 6085344 AWC lp (2025-1749342003702).pdf

Between January 2018 and March 2022, Tranchina recommended to two retail customers a series of trades that were excessive. As a result, Tranchina 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, Tranchina is suspended for five months in all capacities, fined $5,000, and ordered to pay restitution of $60,975 plus interest.
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