Nancy Robyn Ziering (CRD # 2845746, Registered Representative, Chatham, New Jersey) submitted a Letter of Acceptance, Waiver and Consent in which she was fined $60,000 (including disgorgement of $32,720 in commissions paid to her for unsuitable transactions) and suspended from association with any FINRA member in any capacity for nine months. The fine must be paid either immediately upon Ziering’s reassociation with a FINRA member firm following her suspension, or prior to the filing of any application or request for relief from any statutory disqualification, whichever is earlier. Without admitting or denying the findings, Ziering consented to the described sanctions and to the entry of findings that she used communications with public customers, in the form of written financial plans, that contained misleading statements and omitted material information. The findings stated that Ziering failed to obtain approval from her firm to use the communications with clients and failed to arrange for the communications to be filed with FINRA. The findings also stated that Ziering recommended variable universal life (VUL) insurance policies to public customers that were not suitable based on each customer’s financial situation and needs. The findings also included that Ziering dealt unfairly with these public customers in recommending the funding of VUL policies in amounts that were inconsistent with the reasonable expectation that the customers had the financial ability to meet such a commitment.