For a churning conviction,the government (or investor)must establish that the

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For a churning conviction, the government (or investor) must establish that the broker exercised control over the trading in the account. Churning involves excessive trading in an investor's account mostly for the purpose of generating commissions for the broker rather than benefiting the investor. Therefore, the broker must have control over the account's trading to engage in this type of fraudulent activity. The other options - A) wishing to manipulate supply and demand of the stock, B) being reckless, and C) trading being typical for that type of account - may or may not be present in a churning case but are not the main focus.

For a Churning Conviction,the Government (Or Investor)must Establish That the