Vanguard Capital Wealth Advisors, Llc

Allegations: FINRA RULE 2010, NASD RULES 2110, 3030: BLAKE-ZUNIGA FAILED TO PROVIDE PROMPT WRITTEN NOTICE OF AN OUTSIDE BUSINESS ACTIVITY TO HIS MEMBER FIRM. BLAKE-ZUNIGA FORMED A COMPANY BEFORE BECOMING ASSOCIATED WITH HIS FIRM; ONCE HE BECAME ASSOCIATED WITH HIS FIRM, HE DISCLOSED THE COMPANY HE FORMED AS AN OUTSIDE BUSINESS ACTIVITY AND DESCRIBED HIS ROLE AS A PASSIVE INVESTOR WITH NO DAY TO DAY EMPLOYMENT OR MANAGEMENT RESPONSIBILITY. WHILE STILL ASSOCIATED WITH HIS FIRM, BLAKE-ZUNIGA BECAME A DIRECTOR AND THE CEO OF THE COMPANY. THIS WAS A MATERIAL CHANGE IN THE NATURE OF BLAKE-ZUNIGA'S AFFILIATION WITH HIS COMPANY AND, THEREFORE, A NEW OUTSIDE BUSINESS ACTIVITY OF WHICH HE WAS REQUIRED TO PROVIDE THE FIRM WITH PROMPT WRITTEN NOTICE; BLAKE-ZUNIGA FAILED TO PROVIDE THE FIRM WITH THE REQUIRED NOTICE Status: Final Sanction Detail: 30 DAY SUSPENSION 9/19/2011 - 10/28/2011 Summary: FINRA RULE 2010, NASD RULES 2110, 3030: BLAKE-ZUNIGA FAILED TO PROVIDE PROMPT WRITTEN NOTICE OF AN OUTSIDE BUSINESS ACTIVITY TO HIS MEMBER FIRM. BLAKE-ZUNIGA FORMED A COMPANY BEFORE BECOMING ASSOCIATED WITH HIS FIRM; ONCE HE BECAME ASSOCIATED WITH HIS FIRM, HE DISCLOSED THE COMPANY HE FORMED AS AN OUTSIDE BUSINESS ACTIVITY AND DESCRIBED HIS ROLE AS A PASSIVE INVESTOR WITH NO DAY TO DAY EMPLOYMENT OR MANAGEMENT RESPONSIBILITY. WHILE STILL ASSOCIATED WITH HIS FIRM, BLAKE-ZUNIGA BECAME A DIRECTOR AND THE CEO OF THE COMPANY. THIS WAS A MATERIAL CHANGE IN THE NATURE OF BLAKE-ZUNIGA'S AFFILIATION WITH HIS COMPANY AND, THEREFORE, A NEW OUTSIDE BUSINESS ACTIVITY OF WHICH HE WAS REQUIRED TO PROVIDE THE FIRM WITH PROMPT WRITTEN NOTICE; BLAKE-ZUNIGA FAILED TO PROVIDE THE FIRM WITH THE REQUIRED NOTICE. WITHOUT ADMITTING OR DENYING THE FINDINGS, BLAKE-ZUNIGA CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY FOR 30 BUSINESS DAYS. THE SUSPENSION IS IN EFFECT FROM SEPTEMBER 19, 2011, THROUGH OCTOBER 28, 2011.

Allegations: ADVISORY AFFILIATE ACCUSED OF IMPROPERLY USING LEVERAGED AND/OR INVERSE ETF PRODUCTS DURING 2009-2012 IN CLIENT ACCOUNTS FOR MORE THAN ONE TRADING PERIOD DESPITE FULL DISCLOSURE AND USE OF SUCH PRODUCTS FOR HEDGING PURPOSES AND NOT IN VIOLATION OF ANY FIRM POLICIES AND PROCEDURES. Status: Final Sanction Detail: FINRA SUSPENSION UNTIL 02/02/2019 Summary: AFTER HAVING RESIGNED FROM HIS ASSOCIATION WITH BROKER DEALER, VANGUARD CAPITAL, A FINRA REGULATED FIRM IN DECEMBER 2016; MR. BLAKE-ZUNIGA WAS CONDITIONALLY SANCTIONED WITH A $25,000 FINE AND TWENTY-TWO MONTH DEFERRED SUSPENSION, SUBJECT TO RE-ASSOCIATION WITH ANY FINRA REGULATED SECURITIES FIRMS. FINRA ISSUED THIS SANCTION IN APRIL 2017. MR. BLAKE-ZUNIGA HAS NOT BEEN ASSOCIATED OR AFFILIATED WITH FINRA REGULATED SECURITIES FIRMS SINCE DECEMBER 31, 2016, AND HE HAS NO INTENTION OF RE-ASSOCIATING IN THE FUTURE. AS A RESULT, THE STATED CONDITIONAL SANCTION IS BEING HELD IN ABEYANCE. FINRA INITIATED ITS SANCTIONS RELATING TO SUITABILITY ISSUES RELATING TO LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS, AND FOR FAILING TO DISCLOSE LOANS ORIGINATED BY CLIENTS IN VIOLATION OF FIRM POLICY. WHILE MR. BLAKE-ZUNIGA PRESENTED WRITTEN EVIDENCE TO FINRA REGARDING HIS KNOWLEDGE, DUE DILIGENCE, AND APPROPRIATE SUITABILITY OF LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS FOR HIS CUSTOMERS, AND THE AUTHORIZATION OF ALL LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS BY HIS SUPERVISING EMPLOYER; FINRA REGULATORS DID NOT CONCUR WITH HIS ASSESSMENT. WITHOUT ADMITTING OR DENYING THE SPECIFIC FINDINGS PRESENTED BY FINRA, MR. BLAKE-ZUNIGA ENTERED INTO A CONSENT AGREEMENT WITH IN ORDER TO SETTLE THIS MATTER. .

Allegations: BLAKEZUNIGA FAILED TO DISCLOSE TO HIS BROKER-DEALER HIS POSITION AS CEO OR CHIEF EXECUTIVE OF AN ENTITY IN WHICH HE ISSUED PROMISSORY NOTES AND THEREFORE CONDUCTED UNAUTHORIZED OUTSIDE BUSINESS ACTIVITIES. Status: Final Sanction Detail: CEASE AND DESIST $3500 FINE Summary: BLAKEZUNIGA FAILED TO DISCLOSE TO HIS BROKER-DEALER HIS POSITION AS CEO OR CHIEF EXECUTIVE OF AN ENTITY IN WHICH HE ISSUED PROMISSORY NOTES AND THEREFORE CONDUCTED UNAUTHORIZED OUTSIDE BUSINESS ACTIVITIES.