From May 22, 2021, to February 6, 2024, Regulus did not disclose its own and its control affiliate’s disciplinary history in the firm’s customer relationship summary (Form CRS). By filing and delivering to customers a Form CRS that omitted required information, Regulus willfully violated Section 17(a)(1) of the Securities Exchange Act of 1934 and Exchange Act Rule 17a-14, and violated FINRA Rule 2010 and is fined $20,000...

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS DEPARTMENT OF ENFORCEMENT, Complainant, v. DAVID WONG (CRD No. 4689031), Respondent. Disciplinary Proceeding No. 2021069373001 Hearing Officer–MC HEARING PANEL DECISION April 21, 2025 Respondent David Wong is barred from associating with any FINRA member firm in any capacity for converting and misusing customer funds.

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.