The allegations read: For the sole purpose of resolving an investigation by the texas state securities board, shailesh negandhi consented to the entry of this order. The tssb found that negandhi repeated a pattern of short - term trading in cefs without a reasonable basis to do so and in violation of his firm's policies. These violations constitute an inequitable practice in the sale of securities. Pursuant to section 4007.105(a)(3)(a) of the texas securities act, the aforementioned inequitable practice constitutes a basis for the issuance of an order reprimanding and suspending negandhi.