Churning is trading in a customer’s account that is excessive in light of his investment objectives, for purposes of generating commissions, without regard to the interests of the customer. In a churning case, the customer must prove: 1) that the broker controlled the account; 2) that the trading was excessive in light of investment objectives; and 3) that the broker intended to defraud the customer or acted willfully or recklessly.
https://www.seclaw.com/598churning/
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