The allegations read: Without admitting or denying the findings, revelle consented to the sanctions and to the entry of findings that, without obtaining his member firm's approval, he drafted, signed, and disseminated to third parties asset verification letters on firm letterhead that contained material misrepresentations. The findings stated that the material misrepresentations included incorrectly stating that the individual on whose behalf the letters were sent was a firm customer. In addition, one of the letters materially overstated the value of the individual's assets, including crypto assets, and incorrectly stated that revelle had "verified" the individual's assets, even though he had not taken any steps to do so. The findings also stated that revelle engaged in an oba that he failed to disclose to his firm. Revelle was employed by a third-party entity-a start-up decentralized crypto exchange-to assist the company in processing investments, for which he earned more than $29,000.