The two defendants purchased municipal bonds for a third party, Riccardi. The defendants bought the bonds in their own names, but with Riccardi’s money and immediately transferred the bonds to him. They shared profits on Riccardi’s resale of the bonds. By this means, Riccardi was able to buy more of popular municipal bonds than he otherwise would have been able to under municipal bond sales rules granting retail purchasers priority in initial sales of municipal bonds. Under Securities Exchange Act, a broker–that is a person engaged in the business of effecting transactions in securities for the account of others–must register with the SEC. Defendants were brokers because they traded for Riccardi’s account, puting his capital at risk in their trades, even though defendants shared some of any loss with Riccardi. That defendants shared some risk doesn’t detract from the fact that they traded, at least in part, for Riccardi’s account. Defendants traded for Riccardi, as his agent, executing each order he placed with them to buy municipal bonds. Defendants were liable for failing to register as brokers. One defendant also lying about her zip code so as to obtain a larger allocation of municipal bonds. The opinion also affirms the substantial civil penalties and the injunction that the district court imposed on the defendants.