BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. Cantone Research, Inc., Anthony Cantone, and Christine Cantone, Tinton, NJ, Respondents. DECISION Complaint No. 2013035130101r Dated: January 23, 2026. On remand from the Securities and Exchange Commission for reconsideration of sanctions. Held, sanctions affirmed in part and modified in part.

It has been determined that the Offer be accepted and that findings be made as follows: This case involves “banking-as-a-service,” a business model that allows financial technology companies (“fintechs”) to provide online banking services to members of the public (“end users”). The fintechs, which are not banks, partner with licensed banks, which in turn hold end user funds. Non-FINRA member Synapse Financial Technologies, Inc.

From June 30, 2020, until October 2023, GMS Group 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 (Reg BI), in violation of Reg BI, MSRB Rule G-27, and FINRA Rules 3110 and 2010.

Between August 2020 and February 2021, Independence Capital and Twarogowski failed to reasonably supervise five representatives' recommendations ofGWG L Bonds. Independence Capital also failed to establish and maintain written procedures reasonably designed to achieve compliance with Reg BI.