The allegations read: Without admitting or denying the findings, donnell consented to the sanctions and to the entry of findings that he exercised discretion without prior written authorization by executing transactions in customer accounts. The findings stated that although the customers had given donnell express or implied authority to exercise discretion in their accounts, none of the customers provided written authorization for him to exercise discretion. The findings also stated that donnell caused two of his member firms to maintain inaccurate books and records by mismarking solicited trades as unsolicited. All of the trades were in marijuana securities, which trade over the counter. At one of the firms, donnell untruthfully answered the firm's direct inquiries about the solicited vs. Unsolicited nature of the trades. While associated to another firm, donnell marked the trades as unsolicited in order to avoid the firm's trade system block on solicited over-the-counter trades.