2022074289902 Independence Capital Co., Inc. CRD 24723 and Dennis C. Twarogowski CRD 1033169 AWC lp.pdf
Between August 2020 and February 2021, Independence Capital and Twarogowski failed
to reasonably supervise five representatives' recommendations ofGWG L Bonds.
Independence Capital also failed to establish and maintain written procedures reasonably
designed to achieve compliance with Reg BI.