Between January 2019 and June 2023, Stash Capital failed to establish and maintain a customer identification program that was reasonable in light of the size and nature of the firm’s business and customer base in violation of FINRA Rules 3310(b) and 2010.

Between November 2022 and January 2024 (the “Relevant Period”), while registered with member firm Pruco Securities, LLC (“Pruco” or “the firm”), Avinesh Shankar forged 643 customers’ signatures on 115 annuity applications without the customers’ prior knowledge or consent. Shankar submitted the forged annuity applications to the firm and received from the firm advanced payment on commissions for the associated annuities. The annuities were never funded. In total, Shankar received $511,609.74 in commissions to which he was not entitled.

Between April 2021 and June 2025, Alpaca failed to timely report to the FINRA/Nasdaq Trade Reporting Facility (FNTRF) approximately 1.87 million transactions, in violation of FINRA Rules 6380A and 2010. From February 2021 to May 2023, Alpaca submitted inaccurate trade reports to the FNTRF and the Over-the-Counter Reporting Facility (ORF). The firm reported inaccurate execution quantities for over 6,700 transactions and omitted the required prior reference price modifier and prior reference time for approximately 2.2 million transactions, in violation of FINRA Rules 6380A, 6622, and 2010.