The allegations read: Nasd rule 2110 - a member firm, acting vicariously through respondent law, participated in contingency offerings of securities and in contravention of section 15(c) of the securities and exchange act of 1934 and rule 15c2-4, respondent firm did not transmit to a proper escrow account investor funds raised in the offerings. Additionally, in contravention of section 15(c) of the exchange act and rule 10b-9 thereunder, investor funds were withdrawn from the bank account into which they were deposited before the minimum offering amount was raised and while the minimum contingency amount was never raised as to some of the offerings, investors in these offerings did not receive reimbursement of their funds.
