Alfred Sietze Vanderlaan, of Watertown, South Dakota, a stockbroker previously registered with WestPark Capital Inc., was the subject of a regulatory action initiated by Financial Industry Regulatory Authority (FINRA), who found that Vanderlaan recommended speculative, unrated corporate bonds known as GWG Holdings Class L Bonds to customers between August 2020 and February 2021, violating Regulation Best Interest, Rule 15l-1(a)(1) of Securities Exchange Act of 1934 (Reg BI) and FINRA Rule 2010. Letter of Acceptance, Waiver, and Consent (AWC) No. 2021070498106 (January 22, 2025).
According to the AWC, Vanderlaan consented to a $10,000 fine, restitution of $6,508 plus interest, and a three-month suspension from associating with any FINRA member in all capacities, effective from February 3, 2025, to May 2, 2025.
Vanderlaan’s recommendations to the two customers were unsuitable based on their investment profiles. Customer A, a senior investor with a moderate risk tolerance, an annual income of $80,000, and a liquid net worth of $912,000, was advised to invest $50,000 in GWG Holdings Class L Bonds despite already having $135,000 in other alternative investments. This recommendation increased Customer A’s alternative investments to over 20 percent of his liquid net worth. Similarly, Customer B, who had a moderate risk tolerance, an annual income of $700,000, and a liquid net worth of $1,000,000, was advised to invest an additional $100,000 in December 2020 and another $15,000 in February 2021 in GWG Holdings Class L Bonds despite already holding $100,000 in the same bonds and $15,000 in other alternative investments. These transactions resulted in over 21 percent of Customer B’s liquid net worth being concentrated in GWG Holdings Class L Bonds.
Vanderlaan’s recommendations violated Regulation BI’s Care Obligation, which requires broker-dealers and their representatives to act in the best interest of their customers without prioritizing their financial gain over the customers’ interests.
In addition to the regulatory action, FINRA Public Disclosure shows five pending customer initiated investment related disputes containing allegations of Vanderlaan’s conduct. On September 26, 2023, a customer initiated investment related FINRA securities arbitration claim was filed, alleging breach of contract, violation of state securities statutes, breach of fiduciary duty, and misrepresentations of material fact, with a damage request of $100,000. FINRA Arbitration No. 23-02613.
Another pending customer initiated investment related FINRA securities arbitration claim filed on July 28, 2023, alleged negligence, misrepresentation and omissions of material fact, breach of fiduciary duty, failure to supervise, and unsuitable recommendations, with a damage request of $40,000. FINRA Arbitration No. 23-02087.
A separate customer initiated investment related FINRA securities arbitration claim filed on June 30, 2023, alleged breach of fiduciary duty, negligence, misrepresentation, breach of contract, failure to supervise, and violation of Reg BI, with a damage request of $105,000. FINRA Arbitration No. 23-01873. Another pending customer initiated investment related FINRA securities arbitration claim from June 16, 2023, alleged breach of fiduciary duty, negligence, breach of contract, failure to supervise, and violation of Reg BI, with a damage request of $50,000. FINRA Arbitration No. 23-01745.
Additionally, a March 21, 2023, customer initiated investment related FINRA securities arbitration claim alleged that WestPark Capital made unsuitable investment recommendations, failed to disclose material facts, and failed to supervise, with a damage request of $315,000. FINRA Arbitration No. 23-00613.
Vanderlaan’s employment history includes WestPark Capital Inc. (2019–2022) and Sandlapper Securities LLC (2011–2019), Throughout his career, Vanderlaan was associated with firms that have since faced regulatory scrutiny, including Sandlapper Securities LLC, which was expelled by FINRA in June 2020, and Capwest Securities Inc., which was expelled by FINRA in December 2014.
