GWG Holdings, Inc.

For most of its history, GWG purchased life insurance policies through the secondary market in anticipation the policies would generate a profit for GWG when an insured person passed away. To finance the business, GWG sold L bonds to outside investors with a typical annual rate of return of 7%. The revenue allowed GWG to buy insurance policies and to make premium payments on policies. From October 2020 to July 2022, the SEC served GWG no fewer than 13 subpoenas covering dozens of topics, including changes in auditors, calculation of debt on L bonds, marketing and sale of L bonds and financial projections of GWG and Beneficient. The SEC served subpoenas on broker-dealers involved in marketing L bonds through GWG.