UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 41955 / September 30, 1999
ADMINISTRATIVE PROCEEDING
File No. 3 -10060
_______________________________
In the Matter of
ORDER INSTITUTING PUBLIC
ADMINISTRATIVE PROCEEDINGS
SEASONGOOD & MAYER and PURSUANT TO SECTIONS 15(b),
RICHARD D. REIS, 15B(c), AND 19(h) OF THE
SECURITIES EXCHANGE ACT
OF 1934, MAKING FINDINGS AND
Respondents. IMPOSING REMEDIAL SANCTIONS
_______________________________
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate and in the public interest that public administrative
proceedings be instituted pursuant to Sections 15(b), 15B(c), and
19(h) of the Securities Exchange Act of 1934 ("Exchange Act") against
Seasongood & Mayer ("Seasongood") and Richard D. Reis ("Reis")
(collectively, "Respondents").
In anticipation of the institution of these administrative
proceedings, Respondents have submitted Offers of Settlement that the
Commission has determined to accept. Solely for the purpose of this
proceeding and any other proceedings brought by or on behalf of the
Commission, or to which the Commission is a party, and without
admitting or denying the findings herein, except as to jurisdiction
and those facts set forth in Sections II.A., II.B. and II.C., which
are admitted by the Respondents, Respondents consent to the entry of
this Order Instituting Public Administrative Proceedings, Making
Findings, and Imposing Remedial Sanctions ("Order").
Accordingly, it is ordered that proceedings pursuant to Sections
15(b), 15B(c), and 19(h) of the Exchange Act be, and hereby are,
instituted.
II.
On the basis of the Order and the Offers of Settlement submitted by
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
SEASONGOOD & MAYER and PURSUANT TO SECTIONS 15,
The Securities and Exchange Commission deems it appropriate and in the public interest that
In anticipation of the institution of these administrative proceedings, Respondents have
On February 20, 1997, Bramble pleaded guilty in federal court to one count of interstate
During the relevant time period, Seasongood was also a municipal securities dealer registered
It is located in Cincinnati, Ohio, and employs 24 registered representatives.
Richard D. Reis is 52 years old and resides in Cincinnati,
As such, he was responsible for the day-to-day supervision of Seasongood's retail sales
In furtherance of his scheme, Bramble misrepresented to his customers that he would purchase,
he obtained funds from his customers to purchase bearer bonds or obtained bearer bonds from
Bramble then misappropriated these bearer bonds and converted them to cash through resale,
From at least 1990 through August 1996, Seasongood failed reasonably to supervise Bramble
failed to develop and implement effective written policies and procedures identifying and
failed to develop and implement adequate procedures limiting access to sensitive customer
Seasongood shall, prior to the close of business on the tenth business day following the
Seasongood shall retain, within 30 days of the date of the Order, at its expense, an
The Independent Consultant shall conduct a review of Seasongood's supervisory, compliance,
At the conclusion of that review, which in no event shall be more than 120 days after the
Within 150 days of the date of the Order, Seasongood shall in writing advise the Independent
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