It is management's responsibility to supervise each and every Representative and each and every investment account. In order to keep track of the many customers and multitude of accounts that a typical Representative oversees, management must have compliance and oversight procedures in place. Failure of management to generate, follow or enforce these procedures will cause management to be responsible for the losses in addition to the individual Representative. While multiple recoveries are not awarded, a panel of arbitrators will consider the role of management in preventing the losses in the first place, and will hold management liable for failing to supervise the account.

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