The allegations read: . Without admitting or denying the findings, reynolds consented to the sanctions and to the entry of findings that he excessively and unsuitably traded the account of a senior customer with a medium risk tolerance. The findings stated that reynolds recommended high frequency in-and-out trading to the customer, even when the price of his recommended securities did not materially change. The customer relied on reynolds' advice and routinely followed his recommendations. Reynolds recommended transactions in the customer's account that generated total trading costs of $39,436, including $35,950 in commissions.