;s system for categorizing customers and offering debentures according to the customer classification, as well as its supervision were insufficiently stringent because CL did not inspect that the

Picture Entertainment) in form 246-2 to the SEC Office within the specified period after she acquired or disposed Traf shares by herself and through others. So that her aggregate holding of such shares

's system for categorizing customers and offering debentures according to the customer classification, as well as its supervision were insufficiently stringent because CL did not inspect that the