
Each of the FAs opened multiple MSDW accounts for their hedge fund customers to facilitate market timing for the hedge funds. In response to market-timing trades, numerous fund companies sent MSDW “block letters,” rejecting particular trades or restricting the trading of particular accounts, customers, or financial advisors that appeared to be market timing. Many of the block letters stated that the frequent markettiming trading was harmful to the funds’ long-term shareholders. The FAs circumvented the fund companies’ restrictions on market timing by employing a variety of deceptive trading practices. These practices included using accounts not restricted by mutual funds to place market-timing trades, trading under different financial advisor identification numbers, and placing market-timing trades through variable annuity contracts. The FAs placed market-timing trades for their hedge fund customers with hundreds of mutual funds and engaged in practices designed to circumvent restrictions the fund companies imposed on market timing. Through these practices, the FAs willfully violated, and/or aided and abetted the violation of, the antifraud provisions of the federal securities laws.