Between October 2020 and March 2021, Leightey recommended purchases of variable annuities to three customers without a reasonable basis to believe that the transactions were suitable based on the customers’ age, financial situation and needs, liquidity needs, and investment time horizon, among other factors. Accordingly, Leightey violated FINRA Rules 2330 and 2010. In connection with these variable annuity applications, Leightey submitted documents that inaccurately stated the customers sought to invest in variable annuities in order to use the annuitization and death benefit features.