Westpark Capital, Inc.

Allegations: ON 09/16/2021, THE OFFICE OF FINANCIAL REGULATION ("OFFICE") ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT IN THE MATTER OF WESTPARK CAPITAL, LLC ("WESTPARK") THE CHIEF COMPLIANCE OFFICER (PERIODS COVERING JANUARY 1, 2016 TO MAY 8, 2019). WESTPARK NEITHER ADMITTED NOR DENIED THE FINDINGS BUT CONSENTED TO THE ENTRY OF FINDINGS BY THE OFFICE. THE OFFICE FOUND THAT WESTPARK A.) FAILED TO DOCUMENT THE REQUIRED APPROVAL OF SUITABILITY DURING THE EXAM PERIOD OF JANUARY 1, 2016 THROUGH MAY 8, 2019, B.) FAILED TO ADEQUATELY DEMONSTRATE WITH SPECIFICITY THAT IT ADHERED TO THEIR SPMS REGARDING A REVIEW OF THE "CHECKS REC. & FORWARDED BLOTTER" DURING THE 2018 INSPECTION AND C.) FAILED TO TIMELY DISCLOSE A CUSTOMER'S COMPLAINT ON THE REGISTERED REPRESENTATIVE'S FORM U4. Status: Final Sanction Detail: ON 09/16/2021, THE OFFICE ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT WHEREBY WESTPARK NEITHER ADMITTED NOR DENIED THE OFFICE'S FINDINGS BUT AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND TO PAY AN ADMINISTRATIVE FINE OF $10,000.00.WESTPARK SHALL BE JOINTLY AND SEVERALLY LIABLE FOR PAYMENT OF THE FINE. Summary: ON 09/16/2021, THE OFFICE ENTERED A FINAL ORDER ADOPTING THE STIPULATION AND CONSENT AGREEMENT WHEREBY WESTPARK NEITHER ADMITTED NOR DENIED THE OFFICE'S FINDINGS BUT AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF CHAPTER 517, F.S. AND TO PAY AN ADMINISTRATIVE FINE OF $10,000.00.WESTPARK SHALL BE JOINTLY AND SEVERALLY LIABLE FOR PAYMENT OF THE FINE.

Allegations: RESPONDENTS FILED AN INCOMPLETE APPLICATION FOR REGISTRATION AND FAILED TO PROMPTLY UPDATE APPLICATION INFORMATION THAT HAD BECOME INACCURATE, IN VIOLATION OF 409.4-412(D)(1) AND 409.4-406(B) Status: Final Sanction Detail: PERMANENTLY ENJOINED AND RESTRAINED FROM VIOLATING 409.4-412 AND 409.4-406. SHALL MAINTAIN AND ENFORCE WSP. RESPONDENTS PAYMENT OF $7,000 IS SUSPENDED, IF $18,000 IS PAID ON SCHEDULE

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND MAINTAIN A SYSTEM OF SUPERVISION REASONABLY DESIGNED TO SUPERVISE ITS BUSINESS IN COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS). THE FINDINGS STATED THAT THE FIRM'S WSPS DID NOT ADDRESS CMO SUITABILITY, RISK FACTORS, RECOMMENDATIONS OR SUPERVISION, AND THEREFORE, PROVIDED INSUFFICIENT GUIDANCE. WESTPARK'S WSPS ALSO FAILED TO ADEQUATELY SPECIFY THAT EDUCATIONAL MATERIALS MUST BE OFFERED TO CUSTOMERS PRIOR TO THE PURCHASE OF CMOS. CONSEQUENTLY, THE FIRM'S SYSTEM OF SUPERVISION, INCLUDING ITS WSPS, WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS, REGULATIONS AND RULES GOVERNING THIS LINE OF THE FIRM'S BUSINESS. IN ADDITION, THE FIRM'S SUPERVISION AND COMPLIANCE STAFF HAD A LIMITED AND INSUFFICIENT OVERALL UNDERSTANDING OF CMOS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ADEQUATELY IMPLEMENT ITS WRITTEN PROCEDURES. THE FIRM SHOULD HAVE EVALUATED CMOS PRIOR TO ANY RECOMMENDATIONS OR SALES, YET IT CONDUCTED NO REVIEW OR ANALYSIS OF CMOS PRIOR TO PERMITTING ITS REPRESENTATIVES TO SELL CMOS THAT ADDRESSED THE CRITERIA AND CONSIDERATIONS IDENTIFIED IN ITS WSPS. THE FIRM ALSO TOOK NO STEPS TO ENSURE PRODUCT KNOWLEDGE OR OFFER TRAINING TO FIRM REPRESENTATIVES AND SUPERVISORS ON CMOS, OR TO INCREASE SCRUTINY OF THE SUITABILITY OF SUCH PRODUCTS, AS OUTLINED IN ITS WSPS. AS A RESULT, THE FIRM FAILED TO FOLLOW ITS OWN WRITTEN PROCEDURES CONCERNING THE APPROVAL AND SUPERVISION OF COMPLEX PRODUCTS IN CONNECTION WITH ITS SALES OF CMOS. IN ADDITION, THE FIRM'S HEIGHTENED SUPERVISION WAS LIMITED TO GENERIC TOPICS, WHICH WERE FREQUENTLY DISMISSED BY IT AS INAPPLICABLE. THIS APPROACH WAS UNREASONABLE. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO OFFER CMO EDUCATIONAL MATERIALS TO RETAIL INVESTORS PRIOR TO THEIR FIRST CMO PURCHASES MADE. THE FIRM DID NOT HAVE ADEQUATE WSPS IN PLACE THAT MADE CLEAR THIS REQUIREMENT OR DESIGNATED RESPONSIBILITY FOR ENSURING THE OFFERING OF SUCH MATERIALS. CONSEQUENTLY, THE FIRM TOOK INADEQUATE STEPS TO ENSURE THAT SUCH MATERIALS WERE OFFERED. INSTEAD, THE CUSTOMERS WHO PURCHASED CMOS WERE SENT MATERIALS, ONLY AFTER THEIR FIRST PURCHASES, BY THE FIRM'S CLEARING FIRM. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $27,500.

Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGED DEFICIENCIES INCLUDE FAILURE TO HAVE A ROBUST WRITTEN AML PROGRAM TO INVESTIGATE RED FLAGS FOR SUSPICIOUS TRADING ACTIVITY AND HIGH-RISK ACCOUNTS AND FAILURE TO PROPERLY TRAIN A CERTAIN INDIVIDUAL INVOLVED IN THE ACCOUNT DUE DILIGENCE REVIEW. FAILURE TO CAPTURE AN INDIVIDUAL'S COMMUNICATIONS RELATED TO ACCOUNT ACTIVITY AND CLIENT COMMUNICATIONS DURING THE ACCOUNT AND TRADE REVIEW. FAILURE TO ESTABLISH AND MAINTAIN ROBUST WRITTEN PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RULES RELATED TO SUITABILITY, MARKUPS AND MARKDOWNS, BEST EXECUTION AND SELF-SUPERVISION. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $475,000, ORDERED TO PAY $218,160.36, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS, REQUIRED TO RETAIN AN INDEPENDENT CONSULTANT, AND REQUIRED TO CERTIFY IN WRITING THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THIS AWC AND IMPLEMENTED A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULES