The Securities and Exchange Commission (SEC) has initiated administrative proceedings against Andrew M. Komarow for his involvement in a securities trading scheme. Komarow, a resident of Avon, Connecticut, was a registered representative with Broker-Dealer A and Investment Adviser A, as well as other firms, using various d/b/a names including Tenpath Financial Group and The Neurodiversity Index.

The proceedings stem from a complaint filed by the Commission in December 2023, alleging that from October 2022 to January 2023, Komarow engaged in a “free-riding” securities trading scheme. In this scheme, he made unfunded automated clearing house transfers of money totaling $6.9 million from multiple bank accounts to accounts at broker-dealers and engaged in speculative trading with the resulting credits before the transfers were cancelled for insufficient funds. This left the broker-dealers with losses totaling more than $3 million.

On December 20, 2023, the court entered a judgment by consent against Komarow, permanently enjoining him from future violations of Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.

As a result of these findings, the Commission has imposed sanctions on Komarow. He is barred from association with any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally recognized statistical rating organization. Additionally, he is barred from participating in any offering of a penny stock, including acting as a promoter, finder, consultant, agent, or other person who engages in activities with a broker, dealer, or issuer for purposes of the issuance or trading in any penny stock.

Any reapplication for association by Komarow will be subject to applicable laws and regulations governing the reentry process, which may include compliance with the Commission’s order and payment of disgorgement or civil penalties ordered by a court, among other factors.

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