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.

Rodney Louis Bruck
AWC/2009017310501

A customer wrote a check for $7,000 payable directly to Bruck with the intent to establish an “emergency fund.” Bruck deposited the check into a business account he owned and operated and wrote checks to the customer, or to another entity on her behalf, from his business account; annotations on the checks indicate these withdrawals were from the customer’s “emergency fund.” Bruck did not seek approval from his supervisor, nor anyone with his member firm, to commingle the customer’s funds in accounts under his personal control.

Rodney Louis Bruck : Barred