The allegations read: Finra rule 2010, nasd rules 2110 and 2370: pursino borrowed money from two customers, through his company, to provide funding for business capital contrary to his member firm's written supervisory procedures that permitted registered persons to borrow from customers only under limited circumstances. In connection with the loans, pursino drafted and signed promissory notes on behalf of his company. In each instance, he failed to notify or obtain written approval of the loans in advance from his member firm. Pursino's company has repaid a portion of each loan.