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.

From January 2015 through November 2019, Lerner failed to reasonably supervise sales of two illiquid, proprietary limited partnerships to ensure that the sales were suitable for customers given their investment profiles. For his violations of FINRA Rules 3110 and 2010, Lerner is suspended in all principal capacities for one month and fined $10,000.

From October 2015 through March 2019, Tulupnikoff recommended that two customers, a married couple, invest in two illiquid, proprietary limited partnerships without having a reasonable basis to believe the investments were suitable for the customers based on their investment profiles. For his violations of FINRA Rules 2111 and 2010, Tulupnikoff is suspended in all capacities for two months and fined $5,000.

In March 2019, Lerner recommended that a customer invest in an illiquid, proprietary limited partnership without having a reasonable basis to believe that the investment was suitable for the customer based on her investment profile. For his violation of FINRA Rules 2111 and 2010, Lerner is suspended in all capacities for two months and fined $5,000.

Between May 14, 2018 and April 2021, Calton violated MSRB Rule G-15 and FINRA Rules 2232 and 2010 by failing to disclose required mark-up and mark-down information on hundreds of retail customer confirmations. Between July 2018 and May 2022, the firm violated MSRB Rule G-14 by failing to report the correct time of trade to the MSRB's Real-Time Transaction Reporting System (RTRS) for more than 7,800 municipal securities transactions and FINRA Rules 6730 and 2010 by failing to report the correct time of execution to TRACE for more than 1,000 securities transactions.

From February 2021 through the present, AAG Capital failed to establish and maintain written policies and procedures and a supervisory system reasonably designed to comply with Securities Exchange Act of 1934 Rule 15l-1 (Regulation Best Interest or Reg BI) for recommendations to retail customers regarding registered index-linked annuities (RILAs).