FINRA

Without admitting or denying the findings, Kozak consented to the sanctions and to the entry of findings that he engaged in an undisclosed outside business activity when he did not provide written or other notice to his member firm of his outside business activity with a company until, after FINRA inquired about the company. The findings stated that at the request of another registered representative, Kozak conducted due diligence on behalf of the company towards its potential acquisition of another company's assets. At that time, Kozak learned that their firm's customers had invested a total of $530,000 in the other company at the solicitation of the other registered representative, without disclosing those transactions to their firm. The company purchased the other company's assets and Kozak served as the company's chief operating officer, running its day-to-day operations and was primarily responsible for managing the company. The company is still in operation however, Kozak ceased to function as a chief operating officer and has not held any other position in this company since that time. Approximately $300,000 of the firm customers' original investments have not been repaid. The findings also stated that on an annual compliance questionnaire that Kozak completed, he falsely stated that he was in compliance with the firm's prohibition against engaging in outside business activities without giving prior notice and obtaining approval.

Acceptance, Waiver & Consent(AWC)

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

$10,000.00

Suspension

All Capacities,

six months

11/4/2019

5/3/2020

Fines paid in full on July 17, 2020.