NOTE: Stipulations of Fact and Consent to Penalty (SFC); Offers of Settlement (OS); and Letters of Acceptance Waiver, and Consent (AWC) are entered into by Respondents without admitting or denying the allegations, but consent is given to the described sanctions & to the entry of findings. Additionally, for AWCs, if FINRA has reason to believe a violation has occurred and the member or associated person does not dispute the violation, FINRA may prepare and request that the member or associated person execute a letter accepting a finding of violation, consenting to the imposition of sanctions, and agreeing to waive such member's or associated person's right to a hearing before a hearing panel, and any right of appeal to the National Adjudicatory Council, the SEC, and the courts, or to otherwise challenge the validity of the letter, if the letter is accepted. The letter shall describe the act or practice engaged in or omitted, the rule, regulation, or statutory provision violated, and the sanction or sanctions to be imposed.

Steve A. Brubaker
AWC/2008014572501

Brubaker recommended that his customers invest in bearer bonds, falsely representing that the bond issuer was a non-profit entity that helped needy people and had been in existence for 15 years, when in fact, no such securities investment existed. Brubaker provided his customers with fake certificates for the bonds, and used the $180,000 he obtained from the customers for his personal benefit. Also, Brubaker misappropriated $49,000 of insurance proceeds that a customer entrusted to him after misrepresenting to the customer that the proceeds were invested in the bonds, when he had used the funds for his own benefit. 

Steve A. Brubaker: Barred