The allegations read: Without admitting or denying the findings, bush consented to the sanctions and to the entry of findings that he maintained an outside investment account without his member firm's approval. The findings stated that bush had sought the firm's approval to maintain an outside investment account he held at another financial institution. Although the firm denied bush's request to maintain the account and instructed him to close the account or move it to an approved financial institution, bush maintained and transacted in the account for approximately four years. Further, bush falsely attested on four annual compliance questionnaires that all of his outside investment accounts were held at custodians approved by the firm.
