The allegations read: Without admitting or denying the findings, mandel consented to the sanctions and to the entry of findings that he participated in private securities transactions without providing prior written notice to, or receiving prior approval from his member firms. The findings stated that mandel solicited investors, some of whom were firm customers, to invest a total of approximately $815,000 in a tequila production company. Mandel invited investors to promotional events for the company, introduced them to the company's founder, and provided investors with documents regarding the opportunity to invest. Mandel received $5,635.35 from the tequila company and expected to receive a portion of the founder's equity in the company. In addition, mandel falsely stated on his firm's annual compliance questionnaire that he had not participated in private securities transactions outside the firm.