From at least December 2014 to March 2023, CGWM USA failed to establish, maintain, and enforce a supervisory system, including written supervisory procedures, reasonably designed to review its associated persons’ securities transactions for potential violations of securities laws and FINRA rules. As a result, the firm violated FINRA Rules 3110 and 2010. In addition, between 2019 and 2021, CGWM USA failed to reasonably conduct required branch office inspections, or reduce inspections to written reports, in violation of FINRA Rules 3110(c) and 2010.

Between October 2019 and March 2022, Cash App Investing failed to establish and maintain a supervisory system reasonably designed to safeguard customer information. During that period, the firm failed to disable a former employee's access to a data storage location, allowing the former employee to download reports that contained nonpublic personal information of the firm ' s customers. As a result, the firm violated Rule 30(a) of Regulation S-P of the Securities Exchange Act of 1934, and FINRA Rules 3110 and 2010. For these violations, Cash App Investing is censured and fined $375,000.

Between February 2017 and June 2020, Schuur recommended seven variable annuity exchanges to three customers without a reasonable basis to believe that the transactions were suitable based on the customers’ investment profiles and objectives. Accordingly, Schuur violated FINRA Rules 2330, 2111, and 2010. For this conduct, Schuur is suspended for two months in all capacities and fined $5,000.