The allegations read: Without admitting or denying the findings, muhlberg consented to the sanctions and to the entry of findings that he borrowed $11,500 from a customer in violation of his member firm's procedures and he did not inform the firm of the loan. The findings stated that muhlberg repaid the loan. The firm's procedures explicitly prohibited representatives from engaging in such a lending arrangement. The findings also stated that muhlberg falsely represented to the firm in compliance questionnaires that he had not borrowed money from a customer of the firm.
