Massachusetts Securities Division

Due to disclosure incidents, the Division placed conditions on Bruce Zaro's registration as an IAR of Granite in Massachusetts.

Consent Order - Conditional Registration

Undertaking

For a period of 2 years, Granite must (1) supervise Zaro on a heightened basis, (2) locate and retain an independent compliance consultant to monitor and review Zaro's heightened supervision, and (3) have the Compliance Consultant conduct an annual audit.

FINRA

Without admitting or denying the findings, Zaro consented to the sanctions and to the entry of findings that he signed his customer's name on an Individual Retirement Account/Education Savings Account (IRA/ESA) Distribution Request (Distribution Request), without the customer's prior knowledge or authorization. The findings stated that the unauthorized signature caused the transfer of funds from the IRA account to another of the trust's accounts, instead of to the accounts requested by the customer and caused potential tax consequences for the accountholders. The customer discovered the unauthorized signature on the Distribution Request and complained to Zaro's member firm. The firm was able to reverse the transfer and effect the requested distributions prior to the customer incurring any negative tax consequences. The findings also stated that by engaging in this conduct and submitting the Distribution Request to the firm as an original, Zaro caused the firm to maintain inaccurate books and records.

Acceptance, Waiver & Consent(AWC)

Civil and Administrative Penalty(ies)/Fine(s)

$5,000.00

Suspension

All Capacities

two months

2/19/2019

4/18/2019

Fines paid in full on February 7, 2019.

BOLTON GLOBAL CAPITAL

Permitted to Resign

THE FIRM RECEIVED DOCUMENTS FROM MR. ZARO THAT OUR CLIENT'S BENEFICIARIES CLAIMED THEY HAD NOT SIGNED.

CLIENTS STOCK OPTIONS WERE ALLOWED TO EXPIRE WORTHLESS DUE TO MISCOMMUMICATION.

$23,406.87

$23,406.87