The allegations read: Nasd conduct rule 2110, 2210(b)(1), 2210(b)(2), 2210(d)(1)(a), 2210(d)(1)(b), 2210(d)(2)(m) and im-2210-2 - respondent marlow created and caused to be distributed sales literature and advertisements that omited material facts and were misleading, unbalanced, and exaggerated in that the customer proposal letters, seminar announcements and advertisements were based on principles of fair dealing and good faith and did not provide a sound basis for evaluating facts regarding the investment products and strategies they promoted and that contained exaggerated, unwarranted or misleading statements or claims about investment products and strategies; failed to obtain written approval by a registered principal of his member firm for any customer proposal letters, seminar announcements, or advertisements prior to using them with the public; and, failed to maintain final versions of any of the customer proposal letters, seminar announcements, or advertisements reflecting approval by a registered principal of his member firm.
