Between July 2021 and December 2022, Cupello recommended six variable annuity exchanges to senior customers without a reasonable basis to believe that the transactions were suitable. Specifically, Cupello failed to conduct a reasonable comparative analysis of the customers' existing and prospective living benefit riders to detennine whether the customers would benefit from the new riders. Accordingly, Cupello violated FlNRA Rules 2330 and 2010. For these violations, Cupello is suspended for two months in all capacities and fined $5,000.

In February 2026, Matthews refused to provide information and documents requested pursuant to FINRA Rule 8210, in violation of FINRA Rules 8210 and 2010. For these violations, Matthews is barred from associating with any FINRA member in all capacities.

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.