The allegations read: Without admitting or denying the findings, hutcheson consented to the sanctions and to the entry of findings that he engaged in an oba without providing prior written notice and receiving approval from his member firm. The findings stated that hutcheson signed an independent contractor agreement with a company while associated with his firm in which he, among other things, agreed to assist the company to develop its business plan, negotiate partnerships, and to introduce potential investors to the company. The agreement provided that after the company obtained financing, it would pay hutcheson a monthly fee and a percentage of the funds raised by investors. Three of hutcheson's customers from his firm invested in the company for which hutcheson received $13,500. Hutcheson was required to submit a compliance questionnaire disclosing any obas to his firm but did not disclose his involvement with company on it.