The allegations read: Without admitting or denying the findings, valenzuela consented to the sanctions and to the entry of findings that he willfully failed to amend his form u4 to disclose a federal tax lien in the amount of $150,967. The findings stated that during finra's investigation into valenzuela's federal tax lien and the circumstances of his termination from his member firm, valenzuela failed to timely respond to requests for documents and information. The form u5 disclosed the reason for the termination as, management discretion not to implement additional required supervisory procedures.