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 Kerry Lee Broderick ("Broderick" or "Respondent"). In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the "Offer") which the Commission has determined to accept. The Commission finds that Broderick was a registered representative at Broker-Dealer A, which is a dually-registered broker-dealer and investment adviser, when, in December 2022, her supervisor, Andrew M. Komarow ("Komarow"), engaged in a so-called "free-riding" scheme at Broker-Dealer A. Komarow knowingly made unfunded automated clearing house ("ACH") transfers of money from his bank account to his personal brokerage account at Broker-Dealer A and engaged in speculative trading with the resulting credits before the transfers were cancelled for insufficient funds. Komarow's trading resulted in significant losses to Broker-Dealer A. Broderick spoke to representatives at Broker-Dealer A to initiate trades for Komarow and to assure Broker-Dealer A that the trades that Komarow had placed should be processed and were funded. When Broderick participated in those calls, she knew, or was reckless in not knowing, or should have known that the information she was communicating to Broker-Dealer A was false. As a result of this conduct, Broderick both willfully aided and abetted and caused Komarow's violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.
Resolution
Order
Bar
Bar (Permanent)
Registration Capacities Affected
Participating in any Penny Stock offering
Duration
Indefinite
Start Date
6/12/2024
Registration Capacities Affected
Association with a broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or NRSRO
Duration
Indefinite
Start Date
6/12/2024
Sanctions
Cease and Desist
Sanctions
Penny Stock Bar