FINRA

Without admitting or denying the findings, Blood consented to the sanctions and to the entry of findings that he participated in private securities transactions by facilitating the sale of $400,000 of a security to two married couples who were customers of his member firm without providing prior written notice to the firm. The findings stated that Blood introduced the customers to an individual associated with a potential investment in a company that the firm had not approved for sale. The Unit Purchase Agreements for the offering identified the investment interests as unregistered securities. Blood participated in both customers' investments. After making the initial introductions, Blood sent one of the customers the Unit Purchase Agreement, told his contact that the customers would invest $200,000 and ensured that the necessary funds were wired to complete the investment. In connection with the other customers, Blood provided their information to his contact and provided to his contact a non-disclosure agreement executed by the other customers, which was necessary to complete the investment. The customers each invested $200,000 in the company. Blood's participation in these transactions was outside the regular course and scope of his employment with his firm. In addition, Blood falsely attested to his firm that he did not assist, advise, or facilitate any private securities transactions.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All Capacities

four months

2/6/2023

6/5/2023