Between April and September 2022, CIM sold to one investor a private placement offering for which no exemption from registration was available and, therefore, constituted an unregistered distribution of securities in contravention of Section 5 of the Securities Act of 1933, and, thereby, a violation of FINRA Rule 2010. During the same period, CIM failed to reasonably respond to red flags concerning the issuer of that same offering, in violation of FINRA Rules 3110 and 2010.

Between January 2022 and March 2023, Vorpahl Wing conducted a securities business on at least 10 days while failing to maintain its minimum required net capital, in violation of Section 15(c)(3) of the Securities Exchange Act of 1934, Exchange Act Rule 15c3-1, and FINRA Rules 4110 and 2010.

From January 2018 through the present, Frazer Lanier violated MSRB Rules G-27(a), (b ), and (c) by failing to establish, maintain, and enforce a supervisory system and WSPs reasonably designed to achieve compliance with the provisions of MSRB Rule G-37(b) governing political contributions by municipal dealers and MFPs and the provisions of MSRB Rules G-37(c) and (d) governing political contributions by municipal dealers and MFPs through PACs or other conduit entities.