The allegations read: 07-09-00, sec rule 10b-9 , nasd rule 2110 - respondent, represented in the offering memorandum of a private placement that investor funds would be returned if 500 units were not sold without stating a specified time by which the units must be sold and the minimum sales contingency was modified twice during the course of the offering without returning the subscription payments already received and recommencing the offering on the basis of the new minimum contingency.
