Maybe I'm just getting grouchy (or grouchier) in my old age, but seems to me that FINRA sure as hell bent over backwards here in terms of imposing sanctions.  Frankly, I can understand a short suspension and/or very modest fine for a technical violation of the proscription against borrowing/lending activities with clients.  Sometimes there are extenuating circumstances such as old school chums or a blurring of the traditional client/RR lines.  All of those issues I understand and hear about from potential clients of my law practice -- so, yeah, I'm sympathetic to such excuses and explanation, and particularly in these tough times.
Before you accuse me of going over to the other side and being a FINRA agent, please look at this case and explain the difference in outcomes to me: Boardman

HOWEVER, when the RR not only violates the rule BUT also fails to repay the loan AND it's not an isolated, singular loan but loans with an "s" AND that same RR lies about the loans on multiple inspection/compliance forms, well that's asking quite a bit of compassion from a typically pro-broker regulatory lawyers such as me.  If it were up to me, Allen might not get off with anything less than years of suspension if not a bar.  Perhaps there is more to this case than the slight facts provided in the official case squib -- I hope so.