The allegations read: Without admitting or denying the findings, conwell consented to the sanctions and to the entry of findings that he impersonated one of his customers on one occasion in order to obtain a current annuity valuation for a portfolio review that he was providing the customer the following day. The findings stated that conwell called another financial institution in order to obtain current valuation information about the variable annuity owned by the customer to enable conwell to conduct a routine account review. Because conwell was not listed as the registered representative of record on the annuity account at the time, he misrepresented to the financial institution that he was the customer in order to obtain the information. Conwell then used the information obtained about the variable annuity's current value to conduct the portfolio review with the customer.