FINRA

Without admitting or denying the findings, Mezrah consented to the sanctions and to the entry of findings that he sent email communications to retail investors that violated the content standards of FINRA Rule 2210 because they were not fair and balanced, contained promissory, unwarranted, and misleading statements or claims, and included prohibited projections of performance. The findings stated that the emails discussed an opportunity to invest in a multi-family real estate property through a private offering of interests in the company that planned to acquire and develop the property. Mezrah failed to mention any risks of investing in private placements, the specific risks of investing in the particular private placement referred to in the emails, and the real estate risks associated with the investment. The emails, in fact, do not discuss any investments risk.

Acceptance, Waiver & Consent(AWC)

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

$10,000.00

Suspension

All capacities

20 business days

11/20/2023

12/18/2023

The allegations were the result of an email shared on April 2017, more than 6 years ago. email communication was initially allowed by M Securities. Mr. Mezrah has never had any customer complaints. Investment performed better than projected.

M Holdings Securities, Inc.

Discharged

The individual did not follow the firm's policies and procedures concerning outside business activities and private securities investments.

I DISCLOSED TO THE FIRM MY OUTSIDE BUSINESS ACTIVITIES ON WRITTEN NOTICES TO THE FIRM; THE FIRM APPROVED MY ACTIVITIES; AND MY ACTIVITIES WERE CONSISTENT WITH MY DISCLOSURES TO THE FIRM AND FIRM'S APPROVAL. MY OUTSIDE BUSINESS ACTIVITIES DID NOT INCLUDE PRIVATE SECURITIES INVESTMENTS.