ALTIMARI, Circuit Judge:
Petitioners First Independence Group, Inc. ("FIG"), Frank P. Giraldi, and Mark S. Milana (collectively, "petitioners") appeal from an order of the Securities and Exchange Commission ("SEC"), affirming disciplinary action taken against them by the National Association of Securities Dealers ("NASD"). The NASD imposed sanctions on petitioners for, among other things, charging unfair and fraudulent markups to their...
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