The allegations read: Without admitting or denying the findings, higgins consented to the sanction and to the entry of findings that he refused to produce information and documents and refused to appear for on-the-record testimony requested by finra during the course of a matter that originated from an examination by finra following a regulatory tip. The findings stated that higgins' member firm filed a form u5 stating that he was discharged based on his notification to it that he had been misdirecting client investments and funds and misappropriating client investments and funds to his own use, starting at his prior broker-dealer firm, and that these activities have continued through to the date of termination.