Securities Exchange Act of 1934
Release No. 50803 / December 7, 2004

Admin. Proc. File No. 3-11766


In the Matter of

Thomas H. Keesee,

Respondent.



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ORDER INSTITUTING 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, and hereby are, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") against Thomas H. Keesee ("Keesee" or "Respondent").

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the "Offer"), 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 the findings herein, except as to the Commission's jurisdiction over him and the subject matter of these proceedings, and the findings contained in Section III.2 below, which are admitted, Respondent consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange Act of 1934, Making Findings, and Imposing Remedial Sanctions ("Order"), as set forth below.

III.

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

1. For the period of August 2003 though January 2004, Keesee was associated with an unregistered broker-dealer.

2. On November 18, 2004, a final judgment was entered by consent against Keesee permanently enjoining him from, inter alia, future violations of Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933 ("Securities Act") and Sections 10(b) and 15(a) of the Exchange Act and Rule 10b-5 promulgated thereunder, in the civil action entitled Securities and Exchange Commission v. First Access Financial, LLC, et al., Civil Action Number 3:04CV-166-H in the United States District Court for the Northern District of Texas.

3. The Commission's complaint alleged that from August 2003 through December 2003, First Access Financial, LLC and First Access, Inc. (collectively "FAF"), through and at the direction of their principals Thomas H. Keesee and Eduardo Lautieri, conducted a fraudulent, unregistered offering and sale of securities in the form of interests in a pooled foreign currency trading account. Using aggressive cold calling, an Internet website, television infomercials, and paid radio spots, FAF falsely claimed to provide investors access to foreign exchange ("FOREX") markets at the special "Interbank level" supposedly accessible only to the "most profitable" and "largest financial institutions in the world." FAF further falsely claimed to have a crack "Currency Management Team" with a five-year track record of 100% returns, headed by "a world-renowned institutional money manager" who is a "Top 10 certified and rated trader." Through these promotional efforts, FAF raised $243,000 from investors from which Keesee received commissions.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in Respondent Keesee's Offer.

ACCORDINGLY, IT IS HEREBY ORDERED:

Pursuant to Section 15(b)(6) of the Exchange Act, that Respondent Keesee be, and hereby is barred from association with any broker or dealer with the right to reapply for association after three years to the appropriate self-regulatory organization, or if there is none, to the Commission.

Any reapplication for association by the Respondent 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 the Respondent, 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.

By the Commission.

Jonathan G. Katz
Secretary