A broker-dealer and its Chief Financial Officer and Financial Operations Principal ("FINOP") settled FINRA charges for operating a securities business below the net capital requirement.

As summarized in the Letter of Acceptance, Waiver, and Consent (or "AWC"), the broker-dealer and FINOP failed to (i) provide accurate net capital computations, (ii) submit correct Financial and Operational Combined Uniform Single (or "FOCUS") reports, and (iii) maintain accurate records. FINRA also stated that the broker-dealer engaged in firm commitment offerings without approval.

To settle the charges, the broker-dealer agreed to (i) a censure and (ii) a $45,000 fine. The FINOP agreed to (i) a $5,000 fine, (ii) a one-month suspension, and (iii) a requirement to take the requisite examination to re-qualify as a FINOP.

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