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2023080111701 Mark Paverman CRD 1046105 Order Accepting Offer of Settlement lp.pdf
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.
2020065143601 The GMS Group, LLC CRD 8000 AWC lp.pdf
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.
2022074289902 Independence Capital Co., Inc. CRD 24723 and Dennis C. Twarogowski CRD 1033169 AWC lp.pdf
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.
7660B. FINRA/NYSE Trade Reporting Facility Fees for Non-Participants
FINRA members that are not FINRA/NYSE Trade Reporting Facility participants will be charged a monthly fee of $1,000 for read-only access to the NYSE TRF Portal, Drop Copy, and End of Day Journal.
For purposes of this Rule, “NYSE TRF Portal” is a web-based interface provided by the FINRA/NYSE Trade Reporting Facility that allows FINRA members that are not FINRA/NYSE Trade Reporting Facility participants to see trade reports identifying them as a party to the transaction; “Drop Copy” is a service provided by the FINRA/NYSE Trade Re
2024082784301 Robert Wylie Goff CRD 4388671 AWC lp.pdf
From June 2023 to May 2024, Goff exercised discretion without written authorization in 12 customer accounts. As a result, Goff violated FINRA Rules 3260(b) and 2010 and is suspended in all capacities for one month and fined $5,000.