NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.
Allen borrowed $24,815.72 from public customers contrary to his member firm’s written procedures forbidding the borrowing or lending of money unless the client is a member of the registered representative’s immediate family or the client is a financial institution or other entity or person that regularly engages in financing loans, which these customers were not. Also, Allen failed to repay the loans. Allen completed and signed site inspection and compliance interview forms for his firm and misrepresented facts on the forms regarding the loans by stating that he had never borrowed money from a client.
Curtis Morgan Allen: No monetary sanction was imposed because Allen was granted a discharge in bankruptcy after the events in question; Suspended 6 months in all capacities;