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Respondent was found by the SEC to have failed to reasonably supervise four financial advisors, after it did not prevent or detect their violations of the federal securities laws in a fraudulent market timing scheme. The alleged scheme involved thousands of market timing trades in less than two years and generated approximately $1 million or more in net commissions or asset-based fees. Respondent was further found to have failed to make and keep records of customer orders placed after the market close.