UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC ADMINISTRATIVE PROCEEDING RELEASE NO. 34-56543, SEPTEMBER 27, 2007: THIS MATTER INVOLVES MATERIAL MISREPRESENTATIONS, ADJUSTED TRADING AND OTHER UNLAWFUL CONDUCT BY A BROKER-DEALER (THE "FIRM") THAT OPERATES AS A MUNICIPAL SECURITIES "BROKER'S BROKER," AND THE FIRM'S CEO DONALD MICHAEL KECK ("KECK") AS WELL AS SUPERVISORY FAILURES BY THE FIRM, KECK AND ANOTHER SUPERVISOR AT THE FIRM, (COLLECTIVELY "RESPONDENTS"). UNTIL LATE 2006, WHEN THE FIRM CEASED OPERATING, THE FIRM ACTED AS AN INTERMEDIARY FOR OTHER MUNICIPAL SECURITIES BROKER-DEALERS TO PAIR BUY AND SELL ORDERS IN MUNICIPAL BONDS IN BOND AUCTIONS. IN CONNECTION WITH THESE AUCTIONS, THE FIRM AND KECK ENGAGED IN ONE OR MORE OF THE PRACTICES AND VIOLATED VARIOUS SECTIONS AND RULES OF THE EXCHANGE ACT AND THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB"). THE RESPONDENTS FAILED REASONABLY TO SUPERVISE THE FIRM'S TRADERS PURSUANT TO SECTION 15(B)(4)(E) OF THE EXCHANGE ACT WITH A VIEW TOWARDS PREVENTING AND DETECTING THE TRADERS' CONDUCT, WHICH AIDED AND ABETTED AND CAUSED ITS VIOLATIONS OF SECTIONS 15(C)(1)(A), 15B(C)(1) AND 17(A) OF THE EXCHANGE ACT AND 17A-4(B) PROMULGATED THEREUNDER AND MSRB RULES G-13, G-14 AND G-17. KECK, ON BEHALF OF THE FIRM, FAILED TO ESTABLISH REASONABLE PROCEDURES FOR ENSURING THAT THE FIRM'S BID-WANTED AUCTIONS WERE BEING CONDUCTED IN COMPLIANCE WITH THE FEDERAL SECURITIES LAWS. RATHER, KECK KNOWINGLY ALLOWED VIOLATIONS OF THE ANTIFRAUD, TRADE REPORTING AND BOOKS AND RECORDS PROVISIONS OF THE FEDERAL SECURITIES LAWS AND THE MSRB'S RULES. KECK DID NOT ESTABLISH PROCEDURES, WRITTEN OR OTHERWISE, TO PREVENT FRAUDULENT ADJUSTED TRADING. AGAIN, KECK ALLOWED SUCH CONDUCT TO GO ON AT THE FIRM. BY HIS COMPLICITY IN THE FIRM'S MISCONDUCT, KECK AIDED AND ABETTED AND CAUSED THE FIRM'S VIOLATIONS OF MSRB RULE G-27. KECK WILLFULLY VIOLATED SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 PROMULGATED THEREUNDER. (ALLEGATIONS CONTINUED IN THE COMMENTS SECTION)

Order

Monetary/Fine

$15,000.00

Cease and Desist/Injunction

Bar

(SANCTIONS CONTINUED) PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, KECK SHALL CEASE AND DESIST FROM CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15B(C)(1) OF THE EXCHANGE ACT, INCLUDING (1) FAILING TO DEAL FAIRLY WITH ALL PERSONS AND NOT ENGAGE IN ANY DECEPTIVE, DISHONEST OR UNFAIR PRACTICE UNDER MSRB RULE G-17, (2) FAILING TO MAKE AND KEEP CURRENT CERTAIN BOOKS AND RECORDS UNDER MSRB RULES G-8 AND G-9, (3) FAILING TO DISTRIBUTE OR PUBLISH, A QUOTATION RELATING TO MUNICIPAL SECURITIES WHICH REPRESENTS A BONA FIDE BID FOR, OR OFFER OF, MUNICIPAL SECURITIES UNDER MSRB G-13, (4) FAILING TO DISTRIBUTE OR PUBLISH, ACCURATE REPORTS RELATING TO MUNICIPAL SECURITIES UNDER MSRB G-14 AND (5) FAILING TO SUPERVISE THE CONDUCT OF THE FIRM'S ASSOCIATED PERSONS TO ENSURE COMPLIANCE WITH THE MSRB RULES UNDER MSRB G-27. ANY REAPPLICATION FOR ASSOCIATION BY KECK WILL BE SUBJECT TO THE APPLICABLE LAWS AND REGULATIONS GOVERNING THE REENTRY PROCESS, AND REENTRY MAY BE CONDITIONED UPON A NUMBER OF FACTORS, INCLUDING, BUT NOT LIMITED TO, THE SATISFACTION OF ANY OR ALL OF THE FOLLOWING: (A) ANY DISGORGEMENT ORDERED AGAINST KECK, WHETHER OR NOT THE COMMISSION HAS FULLY OR PARTIALLY WAIVED PAYMENT OF SUCH DISGORGEMENT; (B) ANY ARBITRATION AWARD RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER; (C) ANY SELF-REGULATORY ORGANIZATION ARBITRATION AWARD TO A CUSTOMER, WHETHER OR NOT RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER; AND (D) ANY RESTITUTION ORDER BY A SELF-REGULATORY ORGANIZATION, WHETHER OR NOT RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER.

RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. ACCORDINGLY, IT IS ORDERED THAT: PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, KECK SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 PROMULGATED THEREUNDER. PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, KECK SHALL CEASE AND DESIST FROM CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 15(C)(1)(A) AND 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 PROMULGATED THEREUNDER. KECK SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT $15,000 WITHIN 15 DAYS OF ENTRY OF THIS ORDER. PURSUANT TO SECTIONS 15(B)(6) AND 15B(C)(4) OF THE EXCHANGE ACT, KECK BE, AND HEREBY IS BARRED FROM ASSOCIATION WITH ANY BROKER OR DEALER OR MUNICIPAL SECURITIES DEALER WITH THE RIGHT TO REAPPLY FOR ASSOCIATION AFTER ONE YEAR TO THE APPROPRIATE SELF-REGULATORY ORGANIZATION, OR IF THERE IS NONE, TO THE COMMISSION. PURSUANT TO SECTIONS 15(B)(6) AND 15B(C)(4) OF THE EXCHANGE ACT, KECK BE, AND HEREBY IS BARRED FROM ASSOCIATION WITH A BROKER OR DEALER OR MUNICIPAL SECURITIES DEALER IN A SUPERVISORY CAPACITY WITH THE RIGHT TO REAPPLY FOR ASSOCIATION AFTER FIVE YEARS TO THE APPROPRIATE SELF-REGULATORY ORGANIZATION, OR IF THERE IS NONE, TO THE COMMISSION. (SANCTIONS CONTINUED IN OTHER SANCTIONS ORDERED SECTION)