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2019063686211 David Lerner Associates, Inc. CRD 5397 AWC gg (2025-1750378806667).pdf

From January 2015 through November 2019, DLA’s representatives recommended two illiquid, proprietary limited partnerships to thousands of customers. DLA’s supervisory system, however, was not reasonably designed to achieve compliance with FINRA’s suitability rule. DLA also failed to reasonably respond to red flags that its representatives were making unsuitable recommendations of the limited partnerships to customers. In total, DLA, through its representatives, made unsuitable recommendations to 200 customers.