2021070498106 Alfred S. Vanderlaan CRD 1172406 AWC gg (2025-1740183600286).pdf
Vanderlaan recommended that two retail customers invest in GWG L Bonds, which were speculative, unrated corporate bonds. Vanderlaan's recommendations to Customer A in August 2020 and Customer Bin December 2020 and February 2021 were not in the customers' best interests based on their investment profiles. Vanderlaan therefore willfully violated Rule 15/-l(a)(l) under the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rule 2010.