In November and December 2022, WCS failed to reasonably supervise the due diligence of a private real estate offering (Offering) in violation of FINRA Rules 3110 and 2010. From June 30, 2020, to December 2022, WCS also failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Rule 15l-1 of the Securities Exchange Act of 1934 (Regulation Best Interest) and FINRA Rules 3110 and 2010.