In August and September 2020, Scheiman recommended that one retail customer and Franko recommended that three retail customers invest in GWG L Bonds, which were speculative, unrated corporate bonds. These recommendations were not in the customers' best interests, and Scheiman and Franko therefore willfully violated Rule 15/-1(a)(1) under the Securities Exchange Act of 1934 (Reg BI) and violated FINRA Rule 2010. For these violations, Scheiman is suspended for two months in all capacities, fined $5,000, and ordered to pay $2,600 in disgorgement plus interest.

Between October 2023 and December 2023, Scales engaged in an outside business activity without disclosing the business to Fidelity. As a result, Scales violated FINRA Rules 3270 and 2010. For this conduct, Scales is suspended in all capacities for three months and fined $5,000.