The allegations read: Without admitting or denying the findings, tolmacs consented to the sanction and to the entry of findings that he failed to fully respond to requests from finra for documents and information and refused to appear for the continuation of his on-the-record testimony requested by finra during the course of an ongoing finra investigation, into whether tolmacs had entered into lending arrangements with several of his customers through the issuance of promissory notes, and assessing whether those arrangements violated finra rules, whether tolmacs made materially misleading statements and omissions in connection with those arrangements, and whether tolmacs converted customer funds.
