It has been determined that the Offer be accepted and that findings be made as follows: This case involves “banking-as-a-service,” a business model that allows financial technology companies (“fintechs”) to provide online banking services to members of the public (“end users”). The fintechs, which are not banks, partner with licensed banks, which in turn hold end user funds. Non-FINRA member Synapse Financial Technologies, Inc.

From June 30, 2020, until October 2023, GMS Group failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Rule 15l-1(a)(1) of the Securities Exchange Act of 1934 (Reg BI), in violation of Reg BI, MSRB Rule G-27, and FINRA Rules 3110 and 2010.

Between August 2020 and February 2021, Independence Capital and Twarogowski failed to reasonably supervise five representatives' recommendations ofGWG L Bonds. Independence Capital also failed to establish and maintain written procedures reasonably designed to achieve compliance with Reg BI.

From June 2023 to May 2024, Goff exercised discretion without written authorization in 12 customer accounts. As a result, Goff violated FINRA Rules 3260(b) and 2010 and is suspended in all capacities for one month and fined $5,000.