Troy Eric Brown (CRD # 2145769, Registered Representative, Davenport, Florida), Larry Michael Cole (CRD # 4374086, Registered Representative, Windermere, Florida) and Jeffrey David Swanson (CRD # 2385161, Registered Representative, Jacksonville Beach, Florida) submitted Letters of Acceptance, Waiver and Consent in which Brown and Cole were fined $5,000 and suspended from association with any FINRA member in any capacity for 10 business days. Swanson was fined $5,000 and suspended from association with any FINRA member in any capacity for 30 days. The respective fines must be paid either immediately upon their respective reassociation with a FINRA member firm following the suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier. Without admitting or denying the findings, Brown, Cole and Swanson consented to the described sanctions and to the entry of findings that they allowed a subordinate client associate to complete the Firm Element training programs for them by completing the modules and taking the applicable proficiency tests using their user IDs and passwords.

Brown’s and Cole’s suspensions were in effect from January 5, 2009, through January 16, 2009. Swanson’s suspension was in effect from January 5, 2009, through February 3, 2009. (FINRA Cases # 2006004155203/# 2006004155202/ # 2006004155201)