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Mr. Zeeman
Mr. Zeeman started working for the partnership in 1963 as a
clerk/trainee assisting Charles Ogden (a partner) and then Mr.
Krumholz’s father (another partner). Mr. Zeeman later became a
senior trader for petitioner and was registered with the NASD as
a registered representative, a principal, and a financial
operations principal (FINOP). From the mid-1980s until 1992, he
was in charge of petitioner’s back office operation. From June
1, 1991, through May 1997, when he was terminated, Mr. Zeeman’s
duties were primarily administrative, and he largely functioned
as petitioner’s chief financial officer. At various periods
during the years at issue, he served as petitioner’s secretary,
treasurer, vice president, or executive vice president.
Following petitioner’s outsourcing of its back office operation
in December 1992, until his termination from petitioner in May
1997, he was responsible for ensuring that petitioner’s books and
records (including its monthly Financial and Operational Combined
Uniform Single (FOCUS) reports) were prepared and that petitioner
was in compliance with other financial and reporting requirements
imposed by the NASD and the SEC.
Mr. Solomon
Mr. Solomon joined petitioner in 1983. He was a registered
representative with the NASD and rose relatively quickly working
for petitioner. He was given significant authority to trade and
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