Dennis C. Twarogowski

01/27/2026: 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. Accordingly, Independence Capital and Twarogowski violated FINRA Rules 3110 and 2010, and Independence Capital willfully violated Exchange Act Rule 15/-l(a)(l) under the Securities Exchange Act of 1934 (Reg Bl) and violated FINRA Rule 2010 by failing to comply with the Compliance Obligation of Reg BI. For these violations, Independence Capital is censured, ordered to pay $168,680 in partial restitution, plus interest, and agreed to an undertaking. Twarogowski is suspended for three months in all principal capacities, fined $5,000 and agreed to an undertaking to complete 20 hours of continuing education.

Reference 2022074289902data-portal.finra.orgfinra.org