The allegations read: Without admitting or denying the findings, parthemer consented to the sanction and to the entry of findings that he engaged in several outside business activities without providing prior notice to, or receiving approval from, his member firms. The findings stated that parthemer loaned approximately $399,500 to customers of one of his firms without permission. At the time, the firm's procedures prohibited loans to a firm customer unless the customer was an immediate family member of the representative and the loan was not securities related. Parthemer's loans were to customers who not immediate family members, and the loans were not securities related. The findings also stated that parthemer presented to firm customers an undisclosed private security in which the customers ultimately invested in approximately $3.08 million of preferred stock of a company. Parthemer's customer's investments were outside the course and scope of his employment with his firms, and he did not seek or obtain written approval from the firms to participate in the transactions. The findings also included that on multiple occasions parthemer provided false information and false documents in response to finra's request for information. Finra found that parthemer falsely represented to his firms in compliance questionnaires that he was not participating in any outside business activities that required disclosure and that he had not participated in any private securities transactions.
