Between January 2015 and December 2018, Ameriprise failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to supervise recommendations of certain variable annuity exchanges involving contracts with guaranteed lifetime withdrawal benefit (GLWB) riders.

From December 2023 to January 2024, while associated with Merrill Lynch and without the firm’s knowledge or approval, Sorrell prepared, signed, and disseminated three proof of funds letters that contained materially misleading or false statements. Therefore, Sorrell violated FINRA Rule 2010. Sorrell is suspended for nine months and fined $5,000.

From at least January 2018 to February 2025, Cambridge failed to establish and maintain a supervisory system, including written supervisory procedures (WSPs), reasonably designed to surveil rates of deferred variable annuity exchanges. As a result, the firm failed to detect 22 “inappropriate exchanges,” as defined in FINRA Rule 2330(d), by a former registered representative that caused 14 customers to incur $129,938.79 in unnecessary surrender fees. Accordingly, Cambridge violated FINRA Rules 3110, 2330(d), and 2010.

On 17 days between August 2021 and May 2022, Chapin Davis conducted a securities business while failing to maintain the required minimum net capital and failed to notify the SEC or FINRA of those deficiencies.