The Department of Enforcement alleges: 1. Respondent James Fredrick Tighe failed to provide documents and information that FINRA requested pursuant to FINRA Rule 8210, and further failed on two occasions to appear for and provide testimony that FINRA requested pursuant to FINRA Rule 8210.

From February 2021 to March 2023, Hochler failed to reasonably supervise two registered representatives’ recommendations to retail customers. First, from February 2021 to April 2021, Hochler failed to reasonably supervise a registered representative’s (Representative 1) recommendations to purchase GWG L Bonds, a speculative, unrated debt security. Second, from July 2021 to March 2023, Hochler failed to reasonably supervise a registered representative’s (Representative 2) recommendations to purchase non-traditional exchange-traded products (NT-ETPs).