Between August 2021 and October 2022, while registered with FINRA through an association with Grove Point, Shum violated FINRA Rules 3270 and 2010 by engaging in undisclosed outside business activities with a reasonable expectation of compensation. In November 2022, Shum willfully violated Rule 15/-l(a) under the Securities Exchange Act of 1934 (Reg Bl) and violated FINRA Rule 2010 by recommending the purchase of a variable annuity to a retail senior customer that was not in the customer's best interest in light of her investment profile.