For example, allegedly, he did not disclose that he also would be soliciting investments in GPH.

FORBES: Stockbroker's Outside Business Activity Becomes FINRA Private Securities Transaction

That activity not only altered his role at GPH but may well have constituted engaging in private securities transactions, for which separate approval is required.

FORBES: Stockbroker's Outside Business Activity Becomes FINRA Private Securities Transaction

From June 2010 through September 2010, the AWC alleges that Kai solicited four EDJ customers to invest in GPH without giving the firm prior written notice of the proposed transactions and his proposed role.

FORBES: Stockbroker's Outside Business Activity Becomes FINRA Private Securities Transaction