Between at least March 2019 and the present, WestPark violated FINRA Rules 3110 and 2010, and, between June 30, 2020, and the present, willfully violated Regulation Best Interest (Reg Bl), by failing to establish, maintain, and enforce a supervisory system, including written procedures, reasonably designed to achieve compliance with Reg Bi'sCare Obligation and FINRA Rule 2111. As a result, WestPark failed to reasonably supervise recommendations of GWG L Bonds to 10 retail customers that were not in the best interests of or suitable for the customers.

Between January 2021 and September 2023, Merrill Lynch failed to provide material disclosures regarding municipal securities purchased with market discounts for 4,181 transactions involving 1,072 self-directed customer accounts. During this same period, Merrill Lynch failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with the firm’s obligation to provide self-directed customers with all material information concerning municipal securities transactions subject to a market discount at or prior to the time of trade. As a