The allegations read: Rafaloff made untrue statements of material fact or omitted
to state material facts necessary to make the statements made in light of the circumstances under which they were made! not misleading. Rafaloff engaged in dishonest or unethical practices in the securities business. Rafaloff filed a false application with the bureau. Rafaloff is the subject of an order by a self-regulatory organization expelling him from a self-regulatory organization. Rafaloff willfully violated the securities and the regulations promulgated pursuant thereto.
