Our firm is investigating Madison Avenue Securities broker and Buck Wealth Strategies investment advisor representative Daniel Werts (CRD# 6610699) of Lakewood and Denver, Colorado for potential investment-related misconduct tied to illiquid GWG L Bonds private placements.
Financial Advisor’s Career History
According to FINRA BrokerCheck, Daniel Werts has been registered in the securities industry since 2016.
He is currently:
- A broker with Madison Avenue Securities, LLC (CRD# 23224), registered with FINRA as a General Securities Representative since April 7, 2021, working from a branch office at 1 Denver Federal Center, Building 45, Room 1050, Entrance E9, Lakewood, Colorado.
- An investment adviser representative with Buck Wealth Strategies, LLC (CRD# 322138) in Denver, Colorado, approved in Colorado on January 22, 2025.
His prior investment-related registrations include:
- AE Wealth Management, LLC (CRD# 282580) – investment adviser representative in Denver, Colorado from April 2021 to May 2025.
- CL Wealth Management LLC (CRD# 134922) – investment adviser representative from December 2016 to April 2021.
- Cabot Lodge Securities LLC (CRD# 159712) – broker in Denver, Colorado from October 2016 to April 2021.
Werts has also reported other investment-related business activities, including financial planning and educational seminars for federal employees through LTCPro LLC d/b/a Federal Benefits Made Simple, insurance and advisory work through E.A. Buck Insurance d/b/a E.A. Buck Financial Services, and advisory services with Buck Wealth Strategies.
Daniel Werts Fraud Allegations and Investor Complaints Explained
FINRA BrokerCheck discloses one pending customer dispute involving Daniel Werts, categorized as a customer-initiated arbitration related to private placement investments in GWG L Bonds.
According to the disclosure:
- Type of case: Customer dispute – pending arbitration
- Reporting source: Broker
- Employing firm at time of activities: Cabot Lodge Securities LLC (CRD# 159712)
- Product type: “Other: Private placement,” specifically GWG L Bonds
- Allegations:
- Breach of fiduciary duty
- Violations of Regulation Best Interest
- Violations of FINRA Rules 2010, 2020, 2111.05(a), and 3110
- Breach of contract
- Vicarious liability
- Alleged damages: $1,157,000.00
- Date notice/process served: April 25, 2023
- Forum: FINRA arbitration, Case No. 22-01540
- Status: Arbitration pending
- Broker’s statement: Werts states he “was not the registered representative of record for the investments at issue.”
For context, the disclosed events can be summarized as:
- Customer Dispute (Pending, FINRA Arbitration 22-01540):
- Action: Customer-initiated arbitration alleging breaches of fiduciary duty, Regulation Best Interest, and FINRA Rules 2010, 2020, 2111.05(a), and 3110 in connection with GWG L Bonds private placements sold while Werts was associated with Cabot Lodge Securities LLC.
- Claimed damages: $1,157,000.00.
- Disposition/status: Pending; no final award or settlement is reported as of the latest BrokerCheck update.
- Broker response: Werts denies responsibility and asserts he was not the registered representative of record for the GWG L Bonds investments at issue.
Investors should understand that a “pending” disclosure means the allegations have not been proven or adjudicated; the case may be resolved in favor of the broker, settled without any admission of wrongdoing, or result in an award of damages to the investors.
In particular, GWG L Bonds have been the subject of extensive litigation and regulatory scrutiny due to their complex structure, high risk, and illiquidity, especially when recommended to conservative or income-oriented investors who may not have fully understood the potential for principal loss and payment suspensions.
To obtain a copy of Daniel Werts’ FINRA BrokerCheck report, visit this link
Robert Wayne Pearce Is Committed to Recovering Your Investment Losses
FINRA Rule 2111 (Suitability) and Regulation Best Interest (Reg BI) are frequently at the center of customer disputes involving high-risk, illiquid investments such as GWG L Bonds. Rule 2111 requires that a broker or associated person have a reasonable basis to believe that each recommended transaction or investment strategy is suitable for the customer based on the customer’s investment profile—including age, financial situation, risk tolerance, investment objectives, time horizon, and other circumstances. The rule contains three components—reasonable-basis, customer-specific, and quantitative suitability—and FINRA Rule 2111.05(a) emphasizes the “customer-specific” obligation to match the recommendation to the investor’s actual profile rather than a generic risk label.
In a case like the pending GWG L Bonds arbitration, arbitrators would typically examine whether the firm and its representatives:
- Performed adequate due diligence on the GWG L Bonds private placement before recommending it.
- Understood the issuer’s business model, credit risk, and capital structure, especially in light of GWG Holdings’ well-publicized financial distress and bankruptcy.
- Matched the product’s risk, liquidity, and complexity to the client’s stated investment objectives, income needs, and risk tolerance.
- Concentrated too large a portion of the client’s portfolio in GWG L Bonds or other alternative investments, thereby amplifying downside risk.
Where claims allege that elderly, conservative, or income-focused investors were steered into GWG L Bonds or similar alternatives without clear disclosure of their speculative and illiquid nature, investors’ counsel frequently argue that such recommendations violated both FINRA Rule 2111’s customer-specific suitability requirements and Reg BI’s best-interest standard, which demands that brokers place the customer’s interests ahead of their own and mitigate conflicts, including high commission structures.
FINRA Rule 2010 (Standards of Commercial Honor and Just and Equitable Principles of Trade) is a broad ethical rule that underpins virtually every sales-practice case. It requires that firms and their associated persons, “in the conduct of [their] business, shall observe high standards of commercial honor and just and equitable principles of trade.”
In private-placement cases involving complex products such as GWG L Bonds, allegations that a broker:
- Misrepresented or omitted material risks,
- Downplayed the speculative or illiquid nature of the product,
- Emphasized high yields without explaining how those payments depended on the issuer’s financial condition, or
- Failed to disclose conflicts of interest or incentive compensation,
are often framed as violations of Rule 2010 in addition to more specific suitability or disclosure rules. Even if a product technically met some suitability criteria, a pattern of misleading sales presentations or “half truths” can be alleged to fall below the ethical standards required by Rule 2010.
FINRA Rule 2020, which prohibits “manipulative, deceptive or other fraudulent” devices in connection with the purchase or sale of securities, may also be implicated when investors allege outright fraud, deception, or intentional concealment of risk.
In the GWG L Bonds context, investors’ attorneys commonly argue that:
- Describing high-risk, speculative bonds as “safe” or “income” products,
- Failing to disclose issuer liquidity crises or payment suspensions, or
- Structuring recommendations to maximize commissions while downplaying risk,
can amount to deceptive practices that violate Rule 2020 and, by extension, the ethical obligations embodied in Rule 2010. Although the pending claim involving Werts has not been adjudicated, these are the types of legal theories arbitrators frequently consider in similar disputes.
FINRA Rule 3110 (Supervision) shifts attention from individual brokers to the supervisory systems of the brokerage firm. The rule requires every member firm to “establish and maintain a system to supervise the activities of each associated person” that is reasonably designed to achieve compliance with securities laws and FINRA rules, including the requirement to maintain and enforce written supervisory procedures and to conduct regular reviews of business activities.
In large private-placement and GWG L Bond arbitrations, investors frequently allege that the firm:
- Failed to implement effective procedures for reviewing and approving recommendations in high-risk products.
- Did not monitor concentration levels or alternative-investment exposure in customer accounts.
- Ignored or missed red flags in trade blotters, suitability documentation, internal emails, or product due diligence files.
- Allowed representatives to rely on canned marketing materials without ensuring that those materials fairly described the risks.
Where a panel finds that a firm’s supervisory system was inadequate or poorly enforced, Rule 3110 violations can support liability against the brokerage firm even if it is contested whether a particular broker—such as Werts—personally recommended the GWG L Bonds at issue. For investors, these supervisory failures can be critical in establishing firm-level responsibility and recovery, particularly when the individual broker denies involvement or asserts that he or she was not the registered representative of record.
Ultimately, whether the allegations in the pending arbitration against Daniel Werts and his former firm can be proven will depend on the specific documents, testimony, and supervisory evidence presented in the case. However, the Rule 2111 suitability framework, the ethical standards of Rule 2010 and Rule 2020, and the supervisory requirements of Rule 3110 are likely to be central to any analysis of GWG L Bonds recommendations and oversight in this matter.
For over 45 years, Robert Wayne Pearce has helped investors recover losses caused by broker fraud, negligence, and unsuitable recommendations. His firm, The Law Offices of Robert Wayne Pearce, P.A., represents clients nationwide on a no-recovery, no-fee basis. Call (800) 732-2889 or email pearce@rwpearce.com for a free case review with an experienced securities attorney.