SECURITIES EXCHANGE ACT OF 1934
Release No. 42955 / June 19, 2000

ADMINISTRATIVE PROCEEDING
File No. 3-10234


In the Matter of

LINDA BALLOU, RONALD
WACKLER and BRUCE HARLAN,

Respondents.


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ORDER INSTITUTING PUBLIC
ADMINISTRATIVE
PROCEEDINGS PURSUANT TO
SECTION 15(b) OF THE
SECURITIES EXCHANGE ACT
OF 1934, MAKING FINDINGS,
AND IMPOSING REMEDIAL
SANCTIONS


I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be instituted against Linda Ballou ("Ballou"), Ronald Wackler ("Wackler") and Bruce Harlan ("Harlan") (collectively, the "Respondents") pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act").

II.

In anticipation of the institution of these proceedings, each of the Respondents has submitted an Offer of Settlement (the "Offers"), which the Commission has determined to accept. Solely for the purpose of these proceedings 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 any of the findings contained herein, except as to the jurisdiction of the Commission over them and over the subject matter of these proceedings, and the entry of the injunctions set forth in paragraphs III.A.5., which is admitted by Ballou and Wackler, and III.B.4., which is admitted by Harlan, below, and, as to the matters set forth in paragraph III.A.1., which are admitted by Ballou, the matters set forth in paragraph III.A.2., which are admitted by Wackler, and as to the matters set forth in paragraph III.B.1., which are admitted by Harlan, the Respondents consent to the entry of this Order Instituting Public Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange Act of 1934, Making Findings, and Imposing Remedial Sanctions ("Order"), by the Commission.

Accordingly, IT IS HEREBY ORDERED that proceedings pursuant to Section 15(b) of the Exchange Act be, and hereby are, instituted.

III.

On the basis of this Order and the Offers submitted by the Respondents, the Commission finds that:1

A. With respect to Ballou and Wackler:

1. At all relevant times, Respondent Ballou was associated as an officer and director of Desert Financial Group, an unregistered broker-dealer.

2. At all relevant times, Respondent Wackler was associated as a registered representative of LifeUSA Securities, Inc., a broker-dealer registered with the Commission.

3. On May 31, 2000, the Commission filed a complaint ("Complaint") in the United States District Court for the Middle District of Florida, SEC v. Linda Ballou, et al., No. 6:00-CV-692-ORL-19B (M.D. Fla.). Among other things, the Complaint charged Respondents Ballou and Wackler with violations of Sections 5(a), 5(c), 17(a)(1), 17(a)(2) and 17(a)(3) of the Securities Act of 1933 ("Securities Act") and Sections 10(b) and 15(a)(1) of the Exchange Act and Rule 10b-5 thereunder.

4. The Commission's Complaint alleged, among other things, that, with respect to Ballou, between June 1998 and May 1999, and, with respect to Wackler, between November 1998 and April 1999, Respondents Ballou and Wackler made material misrepresentations and omissions in connection with the offer and sale of unregistered securities, in the form of purportedly high interest promissory notes, in Sebastian International Enterprises, Inc. ("SIE"). Their misrepresentations concerned the risk and safety of SIE's securities, the ability of SIE to pay interest and principal on the notes, and the alleged existence of a surety bond guaranteeing the notes. The Commission's Complaint also alleged that Respondents Ballou and Wackler received ill-gotten gains in the form of commission payments from their sale of SIE's securities.

5. On June 8, 2000, the Court permanently enjoined Respondents Ballou and Wackler from future violations of Sections 5(a), 5(c), 17(a)(1), 17(a)(2) and 17(a)(3) of the Securities Act and Sections 10(b) and 15(a)(1) of the Exchange Act and Rule 10b-5 thereunder. Ballou and Wackler consented to the entry of the permanent injunctions without admitting or denying the allegations of the Commission's Complaint.

B. With respect to Harlan:

1. At all relevant times, Respondent Harlan was associated with an unregistered broker-dealer.

2. On May 31, 2000, the Commission filed a complaint ("Complaint") in the United States District Court for the Middle District of Florida, SEC v. Bruce Harlan, et al., No. 6:00-CV-692-ORL-19B (M.D. Fla.). Among other things, the Complaint charged Respondent Harlan with violations of Sections 5(a) and 5(c) of the Securities Act of 1933 ("Securities Act"), and Section 15(a)(1) of the Exchange Act.

3. The Commission's Complaint alleged, among other things, that between August 1998 and August 20, 1999, Respondent Harlan offered and sold unregistered securities, in the form of purportedly high interest promissory notes, in Sebastian International Enterprises, Inc.

4. On June 8, 2000, the Court permanently enjoined Respondent Harlan from future violations of Sections 5(a) and 5(c) of the Securities Act and Section 15(a)(1) of the Exchange Act. Harlan consented to the entry of the permanent injunction without admitting or denying the allegations of the Commission's Complaint.

IV.

On the basis of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in the Respondents' Offers.

ACCORDINGLY, IT IS ORDERED that:

1. Respondents Ballou and Wackler be, and hereby are, barred from association with any broker or dealer, with the right to reapply for association after three (3) years to the appropriate self-regulatory organization, or if there is none, to the Commission.

2. Respondent Harlan be, and hereby is, suspended from association with any broker or dealer for 12 months, effective on the second Monday following the entry of the Order; and

3. Within thirty (30) days after the end of the twelve-month suspension period described above, Respondent Harlan shall provide to the Commission, addressed to Glenn

S. Gordon, Assistant Regional Director, 1401 Brickell Avenue, Suite 200, Miami, Florida, 33131, an affidavit that he has complied fully with the sanctions described in Section IV. of this Order.

By the Commission.

Jonathan G. Katz
Secretary


Footnote

1 The findings herein are made pursuant to the Offers submitted by Ballou, Wackler and Harlan, and are not binding on any other person or entity in this or any other proceeding.