FINRA

Without admitting or denying the findings, Hartwyk consented to the sanctions and to the entry of findings that he exercised discretion without written authorization or obtaining his member firm's approval for trades in customer accounts. The findings stated that FINRA began its investigation after receiving the Form U5 filed by Hartwyk's firm.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All Capacities

15 business days

7/6/2020

7/24/2020

RBC Capital Markets, LLC

Discharged

Violation of Firm policy related to time and price discretion, front running, and order execution

CLIENTS' CLAIM INCLUDES ALLEGATIONS OF MISREPRESENTATION AND OMISSION, UNSUITABILITY, OVER-CONCENTRATION, CHURNING, BREACH OF FIDUCIARY DUTY, BREACH OF CONTRACT AND NEGLIGENCE.

$90,000.00

$49,000.00

CLAIMANTS' CLAIM INCLUDES ALLEGATIONS OF MISREPRESENTATION, OVER CONCENTRATION, UNSUITABILITY, CHURNING, BREACH OF FIDUCIARY DUTY, BREACH OF CONTRACT AND NEGLIGENCE.

$1,500,000.00

$315,000.00

CLAIMANT'S COMPLAINT LETTER COMPLAINS OF UNSUITABLE TRANSACTIONS AND BREACH OF FIDUCIARY DUTY. MR. HARTWYK AND DLJSC DENY THESE ALLEGATIONS.

$265,000.00

CUSTOMER INITIATED ARBITRATION AND DID NOT NAME MR. HARTWYK AS A RESPONDENT.

THE CLIENT ALLEGED THAT THE CONCENTRATION OF SHARES ACCUMULATED IN A CERTAIN SECURITY RESULTED IN POOR ACCOUNT PERFORMANCE.

$53,000.00

A PORTION OF THE SHARES WERE CANCELLED FROM THE ACCOUNT AND I AGREED TO CONTRIBUTE $21,200. TO THE COST, REPRESENTING APPROXIMATELY 40% OF THE COST OF $53,000. Not Provided