customer since 2008. On April 24, 2011, {A} sent a letter that she accepted the trading decisions without the client's instructions. In addition, she had been authorized by her client to make securities

securities trading orders from persons being neither account owner nor account owner's appointee; and failing to keep a complete record of trade order instructions; in violation of Clause 20(2) and (3) of the

authorization that {A} had obtained  to make securities trading decisions on the clients' behalf.In performing their duties, investment consultants  can send trading orders only when obtaining instructions from

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