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Failure to Supervise
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action adopted Advest agreement alleged amendments Amex application arbitration Borrower broker broker-dealers brokerage business days central market system CFTC churning Collateral Comm.Fut.L.Rep commentators Commission Commission's Committee compliance conduct courses of business court DBCC dealer decision defendant Schipa described in paragraph DGSI disciplinary proceedings distribution enforcement engaged Essner Exchange Act Release execution February federal firm fraud Gordon Macklin government securities Heuwetter implementation imposed insider trading investment investors issued issuer l980-l982 Transfer Binder Lender limit orders Loaned Securities market makers Merrill Lynch NASD national market system NYSE options Ossorio Paine Webber participants penalty period permitted person plaintiff procedures proposed purchases pursuant registered regulation repo reporting request respondent Rule sanction Securities Act Securities Exchange Act Securities Industry securities laws self-regulatory organizations Spaulding statement stock loan Supp thereunder trading transactions underwriters Varig violation of Section York York Stock Exchange