In March 2019, Anderson recommended that two senior retail customers invest in GWG L Bonds, which were speculative, unrated corporate bonds. Anderson's recommendations to Customers A and B resulted in at least 96% and 35% of their respective net worth, not including primary residence, being invested in GWG L Bonds. These recommendations were unsuitable based on the customers' investment profiles, and Anderson therefore violated FINRA Rules 2111 and 2010.