From November 2023 to December 2023, Webster recommended that 19 of his customers, at least 13 of whom were seniors, implement a short-term strategy that involved buying stocks in commission-based brokerage accounts rather than in the customers’ existing fee-based advisory accounts at a lower comparative cost. Webster did not have a reasonable basis to believe that buying the stocks at a greater cost in the brokerage accounts was in the customers’ best interests.