Between October 2019 and March 2022, Cash App Investing failed to establish and maintain a supervisory system reasonably designed to safeguard customer information. During that period, the firm failed to disable a former employee's access to a data storage location, allowing the former employee to download reports that contained nonpublic personal information of the firm ' s customers. As a result, the firm violated Rule 30(a) of Regulation S-P of the Securities Exchange Act of 1934, and FINRA Rules 3110 and 2010. For these violations, Cash App Investing is censured and fined $375,000.

Between February 2017 and June 2020, Schuur recommended seven variable annuity exchanges to three customers without a reasonable basis to believe that the transactions were suitable based on the customers’ investment profiles and objectives. Accordingly, Schuur violated FINRA Rules 2330, 2111, and 2010. For this conduct, Schuur is suspended for two months in all capacities and fined $5,000.

BEFORE THE NATIONAL ADJUDICATORY COUNCIL FINANCIAL INDUSTRY REGULATORY AUTHORITY In the Matter of Department of Enforcement, Complainant, vs. John E. Pelletier, Hartland, WI, Respondent. DECISION Complaint No. 2021071094401 Dated: October 1, 2025. Respondent executed unauthorized trades in his customer's account. Held, findings and sanctions affirmed.

Between August 2015 and April 2023, while associated with WFCS, Cairnes engaged in an outside business activity with a firm customer without providing prior written notice to his firm, in violation of FINRA Rules 3270 and 2010. For this violation, Cairnes is suspended for four months in all capacities and fined $2,500.