UNITED STATES OF AMERICA
SECURITIES EXCHANGE ACT OF 1934
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 William J. Bramble, Jr. ("Bramble").
In anticipation of the institution of these administrative proceedings, Bramble has submitted an Offer 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 admitting the findings herein, Bramble consents 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.
On the basis of the Order and the Offer of Settlement submitted by Bramble, the Commission makes the following findings:
A. William J. Bramble, Jr. is 38 years old and was a registered representative of Seasongood & Mayer from July 1989 to September 4, 1996 ("relevant time period").
B. Seasongood & Mayer was formed in 1887, and became a limited partnership in 1944. It has been registered with the Commission as a broker-dealer pursuant to Section 15(b) of the Exchange Act since 1949. During the relevant time period, Seasongood was also a municipal securities dealer registered with the Municipal Securities Rulemaking Board. It is located in Cincinnati, Ohio, and employs 24 registered representatives.
C. Between 1990 and August 1996, Bramble engaged in a scheme to defraud in which he misappropriated six customers' municipal bearer bonds worth approximately $2 million. In furtherance of his scheme, Bramble misrepresented to his customers that he would purchase, sell, or safekeep bearer bonds for their accounts. Based on these misrepresentations, he obtained funds from his customers to purchase bearer bonds or obtained bearer bonds from his customers to sell for their accounts. Bramble then misappropriated these bearer bonds and converted them to cash through resale, liquidation, or by depositing them in a brokerage account at another broker-dealer, where they were margined for cash. Bramble used the proceeds from the bonds to purchase personal assets such as homes, automobiles, an apartment building, and an airplane.
D. Bramble perpetuated and concealed his fraud by, among other things, opening accounts at Seasongood to trade certain misappropriated bearer bonds, which he used to sell those bonds to his customers. Bramble also changed the addresses on his defrauded customer's accounts to that of a post office box that he controlled. By doing so, Bramble was able to intercept legitimate account statements and trade confirmations that would have exposed his fraud. Bramble then created false account statements, trade confirmations, tax forms, and receipts using authentic looking materials he obtained from Seasongood's back office, and sent those false documents to his customers. Those documents misstated his customers' portfolios and misrepresented to them the activity in their accounts.
E. On February 20, 1997, Bramble pleaded guilty in federal court to one count of interstate transportation of stolen securities, arising from the same conduct discussed in Sections II.C. and II.D. of this Order. On June 2, 1997, Bramble was sentenced to 46 months imprisonment. Bramble is currently serving his term of imprisonment at the federal correctional institute in Eglin, Florida. Bramble was also ordered to pay restitution in the amount of $1,500,812.96.
F. Based on Bramble's conduct described in Sections II.C. and II.D. of this Order, Bramble willfully violated Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act, and Rule 10b-5 thereunder.
G. Based on Bramble's criminal conviction described in Section II.E. of this Order, for theft of securities occurring within the preceding ten years, Bramble is subject to sanctions pursuant to Section 15(b)(6)(A)(ii), Section 15(b)(4)(B)(iii) and Section 15B(c) of the Exchange Act.
In view of the foregoing, it is in the public interest to impose the sanction specified in the Offer of Settlement.
Accordingly, IT IS ORDERED that:
That Bramble be barred from association with any broker, dealer, or municipal securities dealer.
By the Commission.
Jonathan G. Katz