FINRA

Without admitting or denying the findings, Saini consented to the sanctions and to the entry of findings that he participated in a private securities transaction involving his purchase of $500,000 in preferred shares of a privately held marketing company without his member firm's knowledge or approval. The findings stated that before receiving any approval from the firm and without informing the firm, Saini signed a stock purchase agreement and other documents regarding the investment. The next day, the firm, which was not aware that Saini had executed these documents, asked Saini various questions about his request for approval, in an effort to determine whether to approve the transaction. In response, Saini withdrew his request for approval from the firm's system and stated to the firm that he had not funded the investment. Nonetheless, two days later, without informing the firm or obtaining approval, Saini wired the funds for his investment to the company. In connection with an investigation the firm commenced, Saini claimed to the firm that he had not participated in the transaction, even though he had been a preferred shareholder in the company. Approximately a week later, after the firm requested additional information from Saini, Saini admitted to the firm that he had participated in the transaction.

Acceptance, Waiver & Consent(AWC)

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

$7,500.00

Suspension

All capacities

60 days

8/15/2022

10/13/2022

MSWM

Voluntary Resignation

Allegations regarding the representative's participation in an outside private investment without Firm approval and the accuracy of information provided to the firm by the representative about his participation.

I made an outside investment in a private company while employed at Morgan Stanley that did not receive timely approval. I submitted for pre-clearance on the investment 4 weeks before funding was required for the investment into the Series C round of this private company. The time was deemed not adequate for Morgan Stanley compliance to satisfy themselves that I had not solicited any of the firm's clients for investment in this private company. I had NOT and told them so. Infact, the investment opportunity was introduced to me by one of my clients (with plenty of email/text proof). It was never my intent to solicit my clients to invest in this private company and I 100% NEVER did so. I felt that the opportunity to invest in this company was too good to pass up for myself and my family and ultimately funded the investment prior to receiving their approval. Because of the timing of events, I then resigned from the firm. Ultimately as can be seen in the language of my U5, Morgan Stanley did not allege that I solicited any clients for the investment.