The allegations read: Section 10(b) of the securities exchange act of 1934 and rule 10b-5 thereunder, nasd rules 2110, 2330(a), 8210 - respondent sold unregistered securities in the form of promissory notes to public customers and the securities did not have the represented purpose of generating extraordinarily profitable returns for investors but rather had the purpose of promoting an illegal "ponzi" scheme and supporting his personal debt and expenses. The findings stated that daniels' failed to respond to finra requests for information.