particularly the violations of § 11(a) and Rule lla-l(a). He does not explicitly challenge the SEC’s interpretation of those provisions as unreasonable, but does argue that the SEC should have considered the prevailing NYSE interpretation of § 11(a) at the time of the events at issue, found in a 1998 letter from Richard Grasso, then Chairman and CEO of the NYSE, to the SEC (the “Grasso letter”). It allegedly required proof of intent to violate § 11(a) and stated that sharing in the profits of an account did not, by itself, create a able for violations of § 11(a) and Rule lla-l(a) based on its interpretation of when a broker is considered to have an interest in an account. See In re John R. D’Alessio, 79 SEC Docket No. 2786, Exchange Act Release No. 47627, 2003 WL 1787291 (Apr. 3, 2003) (<HOLDING>); see also In re Edward John McCarthy, 81 SEC
holding that an attorney violated rule 84d when he failed to perform any effective action on behalf of his client holding that defendant violated 4b of the act by using false monthly account statements to conceal losses and instead represent that defendants were making profitable trades holding that defendant was not resident of his mothers household even though his drivers license listed his mothers address and he received mail there because he expressed a belief that his residence was in a different location than his mothers home he rented and occupied his own residence and he testified that he was only living with his mother after expiration of his lease until he could find another place to live holding that broker violated  11a and rule llala when he shared in the profits and losses of trades in one of his customers accounts holding that broker willfully aided and abetted manipulative wash and match trades scheme when he knew or had reason to know that such trading was economically irrational