Perkins is the co-owner and chief investment officer of Global Trading Financial (GTF). Perkins’ wife is GTF’s compliance officer. GTF has several dozen retail clients and total assets under management of $70 million. All client assets are managed on a discretionary basis. Perkins frequently makes trades for his clients using an omnibus trading account through a broker/dealer, which allows Perkins to buy and sell securities in a block trade on behalf of multiple clients simultaneously. Perkins regularly allocates the securities purchases to individual client accounts after the market closes. Over one six-month period, Perkins allocates 75% of the profitable trades to nine accounts owned or controlled by Perkins and his wife. At the same time, 82% of the unprofitable trades are allocated to the account of the three largest GTF clients. Perkins’ actions are