The Department of Enforcement alleges: 1. Between November 2022 and January 2024 (the “Relevant Period”), while registered with member firm Pruco Securities, LLC (“Pruco” or “the firm”), Avinesh Shankar forged 64 customers’ signatures on 115 annuity applications without the customers’ prior knowledge or consent. 2. 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. 3.

Cruz refused to provide information and documents and to appear for on-the-record testimony as requested by FINRA pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010. For these violations, Cruz is barred from associating with any FINRA member in all capacities.