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2022074289901 Thomas G. Scheiman CRD 1508288_Stephen M. Franko CRD 2157707 AWC ks (2025-1766017195957).pdf

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.