The allegations read: Without admitting or denying the findings, komarow consented to the sanction and to the entry of findings that he refused to provide on-the-record testimony and to produce documents and information requested by finra in connection with its investigation into the circumstances giving rise to a form u5 filed by his member firm. The findings stated that the firm filed the form u5 disclosing that it had terminated komarow for processing ach instructions for his own account knowing there were insufficient funds, then improperly using credit to place trades, resulting in negative balance. Subsequently, the firm filed an amended form u5 disclosing that its internal review had concluded that komarow had caused a personal account to be opened and ach instructions to be processed, knowing accounts had insufficient funds and used credited funds to engage in trading that generated losses in the personal account, prior to the firm receiving ach rejection due to insufficient funds. In response to finra's requests, komarow produced certain documents to finra, but he did not respond fully to its request for documents and information. Ultimately, komarow neither produced the additional requested documents and information nor appeared to provide on-the-record testimony.
