In November and December 2022, WCS failed to reasonably supervise the due diligence of a private real estate offering (Offering) in violation of FINRA Rules 3110 and 2010. From June 30, 2020, to December 2022, WCS also failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Rule 15l-1 of the Securities Exchange Act of 1934 (Regulation Best Interest) and FINRA Rules 3110 and 2010.

Between February 2016 and October 2019, Carroll violated FINRA Rules 2111, 2330,1122, and 2010 by recommending unsuitable variable annuity exchanges, which caused customers to incur surrender charges. For these and other violations, Carroll is suspended for 12 months and fined $10,000. Between February 2016 and December 2025, the firm’s supervisory system and written supervisory procedures were not reasonably designed to supervise certain exchanges and purchases of variable annuities.