Securities Commissioner Entered Three Unrelated Administrative Orders

Texas State Securities Board

AUSTIN (News Release) - The Securities Commissioner entered three unrelated administrative Orders the week ending September 8, 2023.

Michael Delao was suspended for 90 days and assessed an administrative fine of $5,000 for failing to report a felony charge to the Securities Commissioner within thirty days of its occurrence, in violation of an agency Board Rule. This was the second disciplinary action taken by the Securities Commissioner against Delao and involved the same violation of an agency Board Rule. Delao’s suspension will run concurrently with a 90-day FINRA suspension.

Bison Investment Advisors, LLC was assessed an administrative fine of $20,000 and ordered to comply with an Undertaking requiring Bison Investment Advisors to pay nearly $23,000 to certain customers. This amount represents losses sustained by the customers in connection with Bison’s buy-and-hold strategy of a leveraged ETF. The long-term holding of the leveraged ETF violated Bison’s written supervisory procedures and was therefore a violation of an agency Board Rule.

Titan Securities was assessed an administrative fine of $20,000 and ordered to comply with an Undertaking requiring Titan Securities to pay to certain clients an amount equaling the commissions Titan received in connection with clients’ investments in L Bonds issued by GWG Securities. The Order found that Titan failed to follow its firm-imposed requirements that clients indicate a risk tolerance of “aggressive/speculation” in order to invest in L Bonds and that a client’s investment in L Bonds not exceed certain limits.

Titan also failed to enforce its supervisory system when Titan failed to verify inconsistent information that appeared on customer information forms that Titan had put in place in connection with efforts to comply with Regulation Best Interest. The failures to enforce supervisory procedures violated an agency Board Rule.