Sica refused to appear for on-the-record testimony requested pursuant to FINRA Rule 8210. As a result, he violated FINRA Rules 8210 and 2010 and is barred from associating with any FINRA member in all capacities.

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.