FINRA

Without admitting or denying the findings, Carter consented to the sanctions and to the entry of findings that he engaged in an undisclosed and unapproved private securities transaction when he sold a $25,000 promissory note to an investor without providing prior notice to or obtaining approval from his member firm. The findings stated that Carter solicited the investor to purchase the promissory note relating to a purported real estate investment fund. Carter sold the $25,000 promissory note to this investor and received a $1,250 commission. Later, the fund filed a voluntary Chapter 11 bankruptcy petition. Subsequent judgments issued by the United States District Court for the Southern District of Florida required the fund and its former owner to, among other things, disgorge their ill-gotten gains and also required the former owner to pay a civil penalty. The findings also stated that on an annual compliance questionnaire Carter submitted to the firm he falsely indicated that he had not participated in any private securities activities without first obtaining written approval from the firm and that he not sold promissory notes.

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Disgorgement

$1,250.00

Suspension

All capacities

Two months

6/3/2019

8/2/2019

With respect to Mr. Carter, [Redacted] alleges that he made unsuitable private securities transaction recommendations. The alleged activity dates all occurred in 2016.

$25,000.00

FELONY DWI, DWI ARRESTED 09/20/92, CHARGED 1 COUNT FELONY DWI AMENDED TO MISDAMEANOR DWI ON 02/02/93 PLED GUILTY CASE CLOSE ON 02/22/94

FELONY

CHARGES WERE AMENDED TO 2ND OFFENSE DWI (A MISDEMEANOR IN NEVADA) ON 2/2/93/ A GUILTY PLEA WAS ENTERED &ACCEPTED BY THE COURT ON THE MISDEMEANOR CHARGE. CASE WAS COLSED 2/11/94 AFTER ALL COUNSELING,PENALTIES & JAIL TIME WAS SATISFIED. PLED GUILTY AMENDED COMPLAINT OF 2ND OFFENSE DRIVING WHILE UNDER INFLUENCE, 09/19/92, 5DAYS JAIL. $600 PENALTY, LONG TERM TREATMENT PROGRAM, 9 MONTHS E 02/02/93 PAID ON 02/04/94.

DWI ON 09/19/92, ARRESTED PLED GUILTY ON 02/22/94 TO 2ND OFFENSE DWI COMPLETED LONG TERM TREATMENT PROGRAM SERVED 10 DAYS IN JAIL PAID $600 FINE CLOSED 02/22/94.