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2018056490327 Michael J. Dugan CRD 2824966 AWC gg (2025-1746145196658).pdf

Between May 2017 and April 2022, Dugan recommended to two retail customers a series of trades that were excessive, unsuitable, and not in the customers’ best interests. As a result, Dugan willfully violated the Best Interest Obligation under Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and violated FINRA Rules 2111 and 2010. For these violations, Dugan is suspended for seven months in all capacities.