UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC ADMIN RELEASE 34-66205, JANUARY 20, 2012: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST LEO T. BUGGY ("RESPONDENT"). THE COMMISSION FOUND THAT ON JULY 17, 2009, BUGGY PLED GUILTY TO ONE COUNT EACH OF MAIL FRAUD, WIRE FRAUD, AND MONEY LAUNDERING IN VIOLATION OF TITLE 18 UNITED STATES CODE, SECTIONS 1341, 1343, AND 1957, BEFORE THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF WYOMING, IN UNITED STATES V. LEO T. BUGGY, NO. 09-CR-190-B. ON OCTOBER 16, 2009, BUGGY WAS SENTENCED TO A PRISON TERM OF 46 MONTHS FOLLOWED BY THREE YEARS OF SUPERVISED RELEASE AND ORDERED TO MAKE RESTITUTION IN THE AMOUNT OF $1,220,067.80. THE COUNTS OF THE CRIMINAL INFORMATION TO WHICH BUGGY PLED GUILTY ALLEGED, INTER ALIA, THAT BUGGY KNOWINGLY DEVISED AND INTENDED TO DEVISE A SCHEME AND ARTIFICE TO DEFRAUD AND TO OBTAIN MONEY FROM HIS CLIENTS AT A BROKER-DEALER BY MEANS OF FALSE AND FRAUDULENT PRETENSES, REPRESENTATIONS, AND PROMISES, WHICH SCHEME WAS FURTHERED BY THE USE OF WIRE COMMUNICATIONS AND THE MAIL.

Order

Bar (Permanent)

ASSOCIATION WITH ANY BROKER, DEALER, INVESTMENT ADVISER, MUNICIPAL SECURITIES DEALER, MUNICIPAL ADVISOR OR TRANSFER AGENT

Indefinite

1/20/2012

ASSOCIATION WITH ANY NATIONALLY RECOGNIZED STATISTICAL RATING ORGANIZATION

Indefinite

1/20/2012

PARTICIPATING IN ANY OFFERING OF PENNY STOCK

Indefinite

1/20/2012

FINRA

FINRA RULES 2010, 8210, NASD RULES 2110, 2330(A): BUGGY MISUSED CUSTOMERS' FUNDS TOTALING IN EXCESS OF $589,000.00 THROUGH HIS PURPORTED INVESTMENT RECOMMENDATIONS TO HIS MEMBER FIRM'S CUSTOMERS. BUGGY SOLICITED HIS FIRM'S CUSTOMERS TO WITHDRAW FUNDS FROM THEIR EXISTING VARIABLE ANNUITY AND/OR BROKERAGE ACCOUNTS AND INVEST THE WITHDRAWN AMOUNTS IN WHAT BUGGY REPRESENTED TO BE SAFER, HIGHER YIELD INVESTMENTS WITH HIS MEMBER FIRM'S AFFILIATE. THE CUSTOMERS AGREED TO THE PURPORTED INVESTMENT RECOMMENDATIONS, DEPOSITED THE WITHDRAWALS INTO THEIR RESPECTIVE PERSONAL BANK ACCOUNTS, PROVIDED BUGGY WITH CHECKS MADE PAYABLE TO THE AFFILIATE, THAT WERE SUBSEQUENTLY DEPOSITED INTO AN ACCOUNT AT A THIRD PARTY BANK, AN ACCOUNT THOUGHT BY THE CUSTOMERS TO BE THE AFFILIATE'S ACCOUNT, BUT WAS ACTUALLY AN ACCOUNT THAT BUGGY CONTROLLED, AND THE CUSTOMERS ALSO PROVIDED WIRED FUNDS TRANSFERS TO THAT ACCOUNT IDENTIFYING THE AFFILIATE AS BENEFICIARY. BUGGY FAILED TO INVEST ANY OF THE FUNDS HE RECEIVED BUT INSTEAD CAUSED THE FUNDS TO COME UNDER HIS CONTROL, AND MADE IMPROPER USE OF THE FUNDS. BUGGY FAILED TO RESPOND TO FINRA REQUESTS FOR INFORMATION AND DOCUMENTS.

Decision & Order of Offer of Settlement

Bar (Permanent)

All Capacities

Indefinite

6/25/2010

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, BUGGY CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY.

18 U.S.C. 1341/MAIL FRAUD

Convicted

18 U.S.C. 1957 (A)& (B)(1)/MONEY LAUNDERING

Convicted

18 U.S.C. 1343/WIRE FRAUD

Convicted