The allegations read: Finra rule 2010, nasd rule 2510: osborn used discretion on several occasions to buy or sell inverse floater collateralized mortgage obligations (cmos) on behalf of two of his customers without having obtained prior written authorization from them to exercise discretion and prior written acceptance of their accounts as discretionary from his member firm. Although osborn's firm permitted discretionary trading, he was required by the firm's written supervisory procedures to obtain prior written approval from the firm before engaging in any discretionary trading activities.