MEMORANDUM & ORDER
GORTON, District Judge.
The defendant, Daniel R. Howard ("Howard"), was fined by the National Association of Securities Dealers ("NASD," which has since changed its name to the Financial Industry Regulatory Authority, or "FINRA") in the amount of $28,484.25 for improper recommendations to his clients and reporting violations. His appeals of that fine to the United States Securities and Exchange Commission ("the SEC") were unsuccessful...
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