 In 2010, one of the officers of the company was accused of unlawful activity in issuing and offering 2 promissory notes to DFFS clients.In an administrative proceeding, the Commission alleged, in connection with the offering of the promissory notes by the officer, that Frishberg, as CEO, failed to properly supervise the officer who was accused of making false or misleading statements about the offerings.In doing that, the Commission alleged that Frishberg failed to ensure that complete and accurate information about the issuers’ finances was disclosed.