From October 2020 through February 2021, Barringer recommended—without having a reasonable basis in light of the customers’ investment profiles—that four customers invest in GWG L Bonds, a speculative, unrated debt security. As a result, the customers were overconcentrated in GWG L Bonds, either alone or in combination with other alternative investments.

From June 2019 to June 2024, Kim violated FINRA Rules 3270 and 2010 by participating in an outside business activity without providing prior notice to his firm. For this violation, Kim is suspended for three months in all capacities and fined $5,000.

American Trust has failed to reasonably supervise several areas since at least June 2020. From July 2020 to April 2021, the firm violated FINRA Rules 3110 and 2010 by failing to reasonably supervise sales of GWG L Bonds for compliance with Regulation Best Interest (Reg BI) and FINRA Rule 2111. In addition, since June 30, 2020, the firm also has failed to establish policies and procedures, and a supervisory system, reasonably designed to achieve compliance with Reg BI, thus willfully violating Securities Exchange Act Rule 15l-1(a)(1), and violating FINRA Rules 3110 and 2010.

In March 2017, Roth borrowed $250,000 from a customer while associated with International Asset Advisory, LLC. In March 2020, while Roth was associated with Newbridge, Roth and the customer executed a promissory note to memorialize the terms of the March 2017 loan. Through this conduct, Roth violated FINRA Rules 3240 and 2010. For these violations, Roth is suspended for three months.

From April 2022 to the present, SpeedRoute failed to establish, document, and maintain risk management controls and supervisory procedures reasonably designed to manage the financial risks associated with its provision of market access, in violation of Section 15(c)(3) of the Securities Exchange Act of 1934, Exchange Act Rules 15c3-5(b), 15c3-5(c)(1)(i), and 15c3-5(c)(1)(ii), and FINRA Rules 3110 and 2010.