From June 2020 through August 2021, Thurston Springer failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Regulation Best Interest or Reg BI). Separately, Thurston Springer has failed, since June 2020, to establish and maintain a supervisory system reasonably designed to achieve compliance with its obligations to file and deliver customer relationship summaries (Form CRS). As a result, Thurston Springer violated Reg BI and FINRA Rules 3110 and 2010.