The allegations read: Without admitting or denying the findings, dietrich consented to the sanction and to the entry of findings that he did not provide notice to his member firm prior to participating in the soliciting of investors to purchase promissory notes relating to a purported real estate investment fund, nor did he obtain approval from the firm for these private securities transactions. The findings stated that ultimately, dietrich sold $10,831,645 in the purported company's notes to investors, some of whom were the firm's customers. Dietrich received a total of $260,864 in commissions in connection with these transactions. Later, the purported company filed a voluntary chapter 11 bankruptcy petition.