Initiated By
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Allegations
The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pagainst Zigmund Christian Strzelecki ("Strzelecki" or "Respondent"). In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement which the Commission has determined to accept. The commission finds that from approximately June 2021 through April 2022 (the "Relevant Period"), investment adviser representative Strzelecki improperly allocated profitable trades to his personal accounts, family members' accounts, and other affiliated accounts (the "Favored Accounts") at the expense of his other advisory clients. During this period, Strzelecki allocated a disproportionate share of trades with positive first day returns to the Favored Accounts, while allocating a disproportionate share of trades with negative first day returns to other client accounts he managed (the "Disfavored Accounts"). Strzelecki was able to do this by trading equities and options in a master, or omnibus, account and then waiting until later in the day to allocate those trades to his own personal or his clients' accounts. As a result of these uneven allocations, the Favored Accounts received excess profits of approximately $63,928 ($51,312 of which went to Strzelecki's personal accounts), while the Disfavored Accounts suffered corresponding excess losses. By virtue of this conduct, Strzelecki willfully violated Section 206(2) of the Advisers Act.
Resolution
Order
Sanctions
Cease and Desist
Sanctions
Civil and Administrative Penalty(ies)/Fine(s)
Amount
$63,928.00
Sanctions
Disgorgement
Amount
$51,312.00
Sanctions
Monetary Penalty other than Fines
Amount
$8,390.98
Sanctions
Suspension
Registration Capacities Affected
Association with a broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO
Duration
Six months
Start Date
10/7/2024
End Date
4/6/2025
Registration Capacities Affected
Serving or acting as an employee, officer, director, member of an advisory board, IA or depositor of, or Principal Underwriter
Duration
Six months
Start Date
10/7/2024
End Date
4/6/2025
Sanctions
Undertaking