Between January 2024 and April 2024, Galloway falsified six expense reports by claiming he had already incurred expenses when he had not and by doubling the expected amounts of those expenses. As a result, Galloway violated FINRA Rule 2010. For this conduct, Galloway is fined $5,000 and suspended for 5 months in all capacities.

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.