securities via his nominee's securities account but failed to prepare and disclose report on changing in his holding (Form 59-2) to the SEC Office within the period specified in the notification of the

COL securities via his nominee's securities account but failed to prepare and disclose report on changing in his holding (Form 59-2) to the SEC Office within the period specified in the

the credit was not rated and found defects in consideration of important information or factors with respect to the issuer, and this affected its capability to repay the principal and pay interest