U.S. Securities & Exchange Commission
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U.S. Securities and Exchange Commission

UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION

Securities Exchange Act of 1934
Release No. 43722 / December 13, 2000

Investment Advisers Act of 1940
Release No. 1914 / December 13, 2000

Administrative Proceeding
File 3-10387

In the Matter of

ROBIN R. McEACHIN,

Respondent.

ORDER INSTITUTING PUBLIC ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(b)OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(f) OF THE INVESTMENT ADVISERS ACT OF 1940, 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 Robin R. McEachin ("Respondent") pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") and Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act").

In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement ("Offer") which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceeding brought by or on behalf of the Commission or in 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 him and over the subject matter of these proceedings, and as to the findings contained in Section II.A. and the entry of the injunction set forth in Section II.D., which are admitted, Respondent consents to the entry by the Commission of this Order Instituting Public Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange Act of 1934 and Section 203(f) of the Investment Advisers Act of 1940, Making Findings and Imposing Remedial Sanctions ("Order").

Accordingly, IT IS HEREBY ORDERED that proceedings against Respondent be and hereby are instituted.

II.

On the basis of this Order and the Offer, the Commission finds that:

A. Since September, 1991, Meridian Asset Management, Inc. ("Meridian") has been a broker-dealer registered with the Commission and since January, 1992, has been an investment adviser registered with the State of Florida. Respondent McEachin, from September, 1991 through the present, was associated with Meridian.

B. On July 26, 2000, the Commission filed a complaint in the United States District Court for the Northern District of Florida, SEC v. Meridian Asset Management, Inc. and Robin McEachin, et al., Civil Action No. 4:00CV278RH, naming Respondent and Meridian as defendants (the "Complaint"). Among other things, the Complaint charged Respondent with violations, and with aiding and abetting violations by Meridian of certain antifraud and net capital provisions of the federal securities laws.

C. The Commission alleged in the Complaint, among other things, that Meridian was incorporated pursuant to Florida law on September 6, 1991, and that McEachin was the sole owner and president of Meridian from its inception to the present. The Commission further alleged that from at least 1991 through May 2000, McEachin misappropriated at least $1 million, in large part pension funds, which his customers entrusted to him for investment on their behalf. The Commission's Complaint also alleged that to conceal his theft, McEachin created fictitious Meridian account statements reflecting the purported contents and market value of his customers' portfolios. The Commission also alleged in its Complaint that Meridian failed to maintain the minimum net capital required by law, and that it failed, or was in danger of failing, to meet its obligations to its customers.

D. On July 26, 2000, without admitting or denying any of the allegations in the Commission's Complaint, except as to jurisdiction, Respondent consented to the entry of a final judgment of permanent injunction. On August 1, 2000, the Court i) permanently enjoined Respondent McEachin from future violations of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and from aiding and abetting violations of Section 15(c)(3) of the Exchange Act and Rule 15c3-1 thereunder and Sections 206(1) and 206(2) of the Advisers Act.

III.

Based on the foregoing, the Commission deems it appropriate and in the public interest to accept the Offer submitted by Respondent, and accordingly,

IT IS HEREBY ORDERED that:

A. Respondent McEachin be, and hereby is, barred from association with any broker, dealer, or investment adviser.

By the Commission.

Jonathan G. Katz
Secretary

http://www.sec.gov/litigation/admin/34-43722.htm


Modified:12/15/2000