FINRA

Without admitting or denying the findings, Krueger consented to the sanctions and to the entry of findings that he engaged in private securities transactions by issuing $200,000 in convertible promissory notes in connection with his previously disclosed outside business activity and neglected to provide prior written notice to his member firm regarding these securities transactions. The findings stated that Krueger disclosed to his firm as an outside business activity a start-up company he created to develop a social media monitoring app. Five of Krueger's friends - four of whom were Krueger's firm's customers - invested a total of $200,000 in Krueger's company. In exchange for these investments, Krueger, in his capacity as manager of the company, executed convertible promissory notes paying six percent interest. Upon maturity of the notes, each investor could elect to convert the outstanding principal and unpaid interest into equity (based on a formula whereby $50,000 would equal one percent ownership in the company).

Acceptance, Waiver & Consent(AWC)

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

$5,000.00

Suspension

All Capacities

three months

1/2/2018

4/1/2018

Fines paid in full on December 26, 2017.

Stifel Nicolaus & Company Inc.

Discharged

Mr. Krueger was discharged for engaging in outside private securities transactions with Stifel clients.