The allegations read: Without admitting or denying the findings, ziesemer consented to the sanctions and to the entry of findings that he implemented a trading strategy and made unsuitable recommendations to customers to switch from unit investment trusts (uits) to other uits after holding the investments for a short time period. The findings stated that ziesemer's member firm's procedures in place at the time required ziesemer to obtain a "switch letter" signed by the customer before selling any uit and purchasing another uit that carried a sales charge. Although all of the customers' short-term uit trades fell into this category, ziesemer failed to obtain switch letters for any of them. These short-term uit transactions resulted in approximately $160,000 in combined net losses for the customers. In addition, the customers paid total commissions of $64,815 on these transactions, of which ziesemer received $38,889.
