The allegations read: On december 8, 2023, the u.s. District court for the district of connecticut issued this complaint as to defendant andrew m. Komarow ("komarow" or "defendant"). Plaintiff securities and exchange commission alleges as follows against komarow and hereby demands a jury trial. This action involves a $6.9 million "free-riding" securities trading scheme perpetrated by komarow. "free-riding" is a fraudulent practice used by securities traders who seek to exploit the "immediate access" credit extended by certain broker-dealers in advance of incoming deposits of cash from bank accounts. By seeking to transfer funds into his brokerage accounts from his bank accounts that he knew lacked sufficient funds to cover the transfers, komarow exploited the "immediate access" credit extended by certain broker-dealers to buy and sell securities. Generally, immediate access at certain broker-dealers means that those broker-dealers will allow a customer to begin using deposited money immediately to place trades before the customer's check or electronic transfer from another financial account into their brokerage account has actually cleared. Komarow carried out his scheme by trading in his brokerage account during the "immediate access" period when he knew he had insufficient funds in his bank account to cover the transfer into his brokerage account, and thus his brokerage account would never get the money to cover his trading activity. He attempted to earn and withdraw trading profits from his brokerage accounts before the broker-dealers were notified of the insufficient funds in his associated bank accounts and froze his brokerage accounts. Specifically, between october 13, 2022 and january 30, 2023, (the "relevant period"), komarow engaged in a free-riding scheme using his brokerage accounts at four different broker-dealers. During the relevant period, komarow knowingly, or at least recklessly, requested $6.9 million in deposits into 11 of his brokerage accounts at 4 broker-dealers, which were later reversed due to insufficient funds in the bank accounts from which he sought to transfer those funds. Before those fund transfers were reversed, komarow was permitted by the broker-dealers to use some of those funds during the "immediate access" period to engage in speculative securities trading. As a result of his speculative securities trades, komarow made at least $615,031 in profits. Komarow withdrew those profits from his brokerage accounts at one broker-dealer. Komarow's scheme left the four broker-dealers holding his brokerage accounts with losses totaling at least $3,352,407. In addition, to open at least one of his brokerage accounts, komarow made material misrepresentations in his brokerage account opening documents and deceptively used the access credentials (including username and password) of others to access the brokerage firm's online account systems. By this conduct, komarow violated, and unless enjoined will continue to violate, section 10(b) of the securities exchange act of 1934 and rule 10b-5 thereunder. As the result of komarow's violation, the commission seeks permanent injunctive relief, a conduct-based injunction, an officer and director bar, disgorgement with prejudgment interest, and civil penalties against komarow.