Between January 2022 and March 2023, Vorpahl Wing conducted a securities business on at least 10 days while failing to maintain its minimum required net capital, in violation of Section 15(c)(3) of the Securities Exchange Act of 1934, Exchange Act Rule 15c3-1, and FINRA Rules 4110 and 2010.

From January 2018 through the present, Frazer Lanier violated MSRB Rules G-27(a), (b ), and (c) by failing to establish, maintain, and enforce a supervisory system and WSPs reasonably designed to achieve compliance with the provisions of MSRB Rule G-37(b) governing political contributions by municipal dealers and MFPs and the provisions of MSRB Rules G-37(c) and (d) governing political contributions by municipal dealers and MFPs through PACs or other conduit entities.

From August 2020 until July 2024, Hovde Group failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures (WSPs), reasonably designed to review the securities transactions in its associated persons’ outside brokerage accounts for potential violations of securities laws and FINRA rules. As a result, the firm violated FINRA Rules 3110 and 2010.

Dow refused to produce documents requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010.