FINRA Suspends Dennis Twarogowski of Independence Capital for Failure to Supervise GWG L Bond Recommendations to Nine Retail Customers, Including Four Seniors
If you are a current or former customer who purchased GWG L Bonds through Independence Capital Co., Inc. between August 2020 and February 2021, you should know that FINRA has suspended Dennis Twarogowski, the firm’s General Securities Principal and Chief Compliance Officer, following findings that he failed to supervise five registered representatives who recommended GWG L Bonds to nine retail customers, four of whom were seniors, collectively resulting in $443,000 in GWG L Bond purchases and $168,680 in ordered restitution.
Dennis C. Twarogowski (CRD# 1033169), General Securities Principal and Chief Compliance Officer at Independence Capital Co., Inc. (CRD# 24723) in Parma, Ohio.
Without admitting or denying the findings, Twarogowski consented to sanctions and to the entry of findings that he failed to supervise registered representatives under his charge in connection with their GWG L Bond recommendations to retail customers, violating FINRA Rules 3110 and 2010. According to the AWC, between August 2020 and February 2021, five registered representatives under Twarogowski’s direct supervision recommended GWG L Bonds to nine retail customers; four of those customers were seniors. According to the AWC, those nine customers collectively purchased $443,000 in GWG L Bonds. According to the AWC, Twarogowski was the direct supervisor of the registered representatives who made those recommendations and approved each GWG L Bond sale after reviewing the customer application documents. According to the AWC, the customers at issue had risk tolerances of low, moderate, or medium; investment objectives of income; no speculation objective; liquid net worths between $50,000 and $999,999; and GWG L Bond concentrations between 11% and 50% of their liquid net worth. According to the AWC, in approving each of the sales to the nine customers, Independence Capital and Twarogowski failed to perform a reasonable assessment of whether the recommendations were consistent with the customers’ investment profiles, particularly in light of the concentration levels. According to the AWC, GWG Holdings described its L Bonds in offering documents as speculative, illiquid, and high-risk. According to the AWC, GWG Holdings defaulted on its L Bonds in January 2022 and filed for bankruptcy in April 2022.
According to the AWC, Independence Capital Co., Inc. was named as a co-respondent in the same AWC and consented to findings that it willfully violated Regulation Best Interest (Exchange Act Rule 15l-1(a)(1)) and violated FINRA Rules 3110 and 2010, and that it violated FINRA Rule 2010 by failing to comply with Reg BI’s Compliance Obligation; according to the AWC, the firm was censured and ordered to pay $168,680 in partial restitution, plus interest.
According to the AWC, the imposition of a restitution order in the AWC does not preclude customers from pursuing their own actions to obtain restitution or other remedies.
According to BrokerCheck, a customer dispute filed in 2025 under FINRA arbitration case 25-00101 alleges that Twarogowski failed to supervise a registered representative who put customers in a non-existing real estate program; the alleged damages are $100,000. According to BrokerCheck, that complaint is pending.
This complaint is pending and no findings of wrongdoing have been made in connection with it.
GWG L Bonds, Supervision Obligations, and Your Rights
GWG L Bonds were alternative corporate bonds issued by GWG Holdings, Inc., a company that purchased life insurance policies on the secondary market. GWG Holdings described the bonds in its own offering documents as speculative, illiquid, and high-risk. GWG Holdings defaulted on its L Bond interest and principal payments in January 2022 and filed for Chapter 11 bankruptcy in April 2022, leaving L Bond investors facing substantial losses.
FINRA Rule 3110 requires member firms and their supervisory personnel to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws, regulations, and FINRA rules. When a principal approves product recommendations without a reasonable basis to believe those recommendations are suitable for the customers involved, the supervisory system has failed the customers it was meant to protect.
The Compliance Obligation of Regulation Best Interest (effective June 30, 2020) requires broker-dealers to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Reg BI when making recommendations to retail customers. The Compliance Obligation applies at the firm level, and a firm’s failure to build compliant systems is itself an independent violation.
FINRA Rule 2010 requires associated persons to observe high standards of commercial honor and just and equitable principles of trade. A supervisory failure that exposes customers to unsuitable speculative products violates that standard.
FINRA Rule 12206 governs eligibility for arbitration claims. Investors considering a claim should consult with a securities arbitration attorney to evaluate whether their situation falls within the applicable timeframe.
Watch for These Red Flags
If you invested through a brokerage firm and purchased alternative bonds or other speculative fixed-income products, watch for these patterns:
- Alternative or corporate bond products appearing in your account despite a stated investment objective of income or capital preservation
- Recommendations for illiquid or non-traded products when your stated risk tolerance was low, moderate, or medium
- Concentration of 10% or more of your liquid net worth in a single speculative product
- Products described in their own offering documents as speculative, illiquid, or high-risk
- Investments in a company that subsequently defaulted on payments or filed for bankruptcy
If any of these patterns apply to your account, a free consultation with a securities law attorney can help you understand whether you have a potential claim for damages.
Sanctions
According to the AWC, Twarogowski was suspended from associating with any FINRA member in any principal capacity for three months, fined $5,000, and required to complete 20 hours of continuing education concerning Regulation Best Interest. According to BrokerCheck, the suspension ran from February 17, 2026, through May 16, 2026. According to BrokerCheck, the $5,000 fine was paid on February 12, 2026.
According to the AWC, Independence Capital Co., Inc. was censured, ordered to pay $168,680 in partial restitution plus interest to the customers identified in Attachment A of the AWC, and required to comply with a specified undertaking. According to the AWC, the restitution amounts owed to each customer are detailed in Attachment A.
Steps to Take Right Now
- Gather your account statements, trade confirmations, and any correspondence with your broker or firm, including emails, texts, and written materials about the investments.
- Look up your broker on FINRA BrokerCheck at brokercheck.finra.org to review their full disclosure record.
- Contact a securities arbitration attorney for a consultation to evaluate your options.
Rosenberger + Kawabata represents retail investors in FINRA arbitration proceedings involving failure to supervise and unsuitable speculative bond recommendations. Contact Rosenberger + Kawabata online for a free and confidential consultation, or call (310) 894-6921.
The information in this post comes from FINRA’s public records and BrokerCheck database. You can view the full detailed report (CRD# 1033169) here.
You can view the full March 2026 FINRA disciplinary actions report here.