FINRA

FINRA RULE 2010, NASD RULES 2310, 2510(A) AND (B), 3110, INTERPRETATIVE MATERIAL 2310-2, 2310-2(B)(3) - MICHAEL VENABLE RECOMMENDED A HIGHLY SPECULATIVE AND VOLATILE EXCHANGE TRADED FUND (ETF)TO UNSOPHISTICATED CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES AND RISK PROFILES. HALF OF THE ACCOUNTS TRADED THE ETF ON MARGIN, THEREBY INCREASING THE LEVERAGE AND RISK. BASED UPON THE CUSTOMERS' AGE, INVESTMENT OBJECTIVE, RISK PROFILE, ASSETS AND INCOME, THE INVESTMENTS IN THE ETF WERE UNSUITABLE. VENABLE EXERCISED IMPROPER DISCRETION RELATING TO NUMEROUS TRADES IN CUSTOMER ACCOUNTS WITHOUT THE CUSTOMERS' WRITTEN AUTHORIZATION TO EFFECT THE TRADES AND VENABLE'S FIRM HAD NOT APPROVED HIS USE OF DISCRETION IN THE ACCOUNTS. VENABLE EXCESSIVELY TRADED IN ONE CUSTOMER ACCOUNT; THE ACCOUNT WOULD HAVE HAD TO APPRECIATE 140% TO COVER THE COMMISSIONS CHARGED TO THE ACCOUNT. VENABLE FAILED TO MARK TRADE ORDER TICKETS AS "DISCRETION EXERCISED" SO THAT THEY DID NOT REFLECT THAT HE EXERCISED DISCRETION IN THE CUSTOMERS' ACCOUNTS; VENABLE MARKED ORDER TICKETS AS"UNSOLICITED" WHEN FOR THE MAJORITY OF THE TRANSACTIONS, HE EFFECTED "SOLICITED" TRANSACTIONS AND FAILED TO MARK THE ORDER TICKETS ACCURATELY TO REFLECT THAT DESIGNATION, THEREBY CAUSING HIS FIRM TO CREATE AND MAINTAIN INACCURATE BOOKS AND RECORDS.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

3/14/2012

WITHOUT ADMITTING OR DENYING THE FINDINGS, VENABLE CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.

FINRA

RESPONDENT VENABLE FAILED TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.

LETTER

Suspension

ANY CAPACITY

N/A

9/8/2011

PURSUANT TO ARTICLE VI, SECTION 3 OF FINRA BY-LAWS AND FINRA RULE 9554, RESPONDENT VENABLE IS SUSPENDED FOR FAILURE TO COMPLY WITH AN ARBITRATION AWARD OR SETTLEMENT AGREEMENT OR TO SATISFACTORILY RESPOND TO A FINRA REQUEST TO PROVIDE INFORMATION CONCERNING THE STATUS OF COMPLIANCE.