desist from committing or causing any violations and any future violations of Section 17(a)(2) and 17(aX3) of the Securities Act; and • Stifel and David Noack, a former employee, are jointly liable to pay disgorgement and prejudgment interest of $2.44 million. Stifel was also required to pay a civil penalt

desist from committing or causing any violations and any future violations of Section 17(a)(2) and 17(aX3) of the Securities Act; and • Stifel and David Noack, a former employee, are jointly liable to pay disgorgement and prejudgment interest of $2.44 million. Stifel was also required to pay a civil penalt