Between May 2017 and February 2023, Kelly recommended to four retail customers a series of trades that were excessive, quantitatively unsuitable, and not in the customers’ best interests. As a result, Kelly willfully violated the Best Interest Obligation under Rule 15l-l(a)(l) of the Securities Exchange Act of 1934 (Regulation BI or Reg BI) and 2010 in the case of one customer and violated FINRA Rules 2111 and 2010 in the case of three customers. For these violations, Kelly is suspended for nine months in all capacities, fined $10,000, and ordered to pay restitution of $69,830 plus interest.