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.