FINRA

NASD RULES 2110 AND 8210: BETWEEN JANUARY 2003 AND NOVEMBER 2006, STAUFFER MISAPPROPRIATED APPROXIMATELY $531,956.50 FROM CUSTOMERS OF HIS MEMBER FIRM EMPLOYER. GENERALLY, STAUFFER OBTAINED A LETTER OF AUTHORIZATION ("LOA") SIGNED IN BLANK BY A CUSTOMER AND SUBSEQUENTLY, WITHOUT AUTHORIZATION, FILLED IN THE LOA TO DIRECT THAT CHECKS OR WIRE TRANSFERS BE PAID OUT OF THE CUSTOMER'S ACCOUNT. STAUFFER'S GRANDFATHER WAS A CUSTOMER OF THE FIRM. ON OR ABOUT JANUARY 6, 2003, USING A CHECK DRAWN ON THE BASIS OF AN IMPROPER LOA, STAUFFER MISAPPROPRIATED $5,000 FROM THE ACCOUNT OF HIS GRANDFATHER. AGAIN, ON OR ABOUT FEBRUARY 9, 2004, USING A WIRE TRANSFER AUTHORIZED BY AN IMPROPER LOA, STAUFFER MISAPPROPRIATED $2,500 FROM THE ACCOUNT OF HIS GRANDFATHER. STAUFFER'S BROTHER WAS A CUSTOMER OF THE FIRM. ON OR JULY 25, 2003 AND OCTOBER 8, 2003, USING WIRE TRANSFERS AUTHORIZED BY IMPROPER LOAS, STAUFFER MISAPPROPRIATED TWO PAYMENTS, EACH OF $7,500, FROM HIS BROTHER'S ACCOUNT. ON OR ABOUT DECEMBER 9, 2003, AGAIN USING A WIRE TRANSFER AUTHORIZED BY AN IMPROPER LOA, STAUFFER MISAPPROPRIATED A FURTHER $3,500 FROM HIS BROTHER'S ACCOUNT. ON OR ABOUT MAY 5, 2004, USING AN IMPROPER LOA THAT HAD BEEN SIGNED IN BLANK, STAUFFER HAD A CHECK FOR $18,500 DRAWN ON THE ACCOUNT OF HIS CUSTOMER AND DEPOSITED INTO A CREDIT UNION ACCOUNT OWNED BY HIS BROTHER. THIS TRANSFER RESULTED IN THE CUSTOMER'S FUNDS BEING MISAPPROPRIATED. BETWEEN ON OR ABOUT DECEMBER 3, 2003 AND FEBRUARY 7, 2004, STAUFFER WRONGFULLY USED AN ATM CARD DEBIT CARD THAT HAD BEEN ISSUED FOR HIS BROTHER'S ACCOUNT TO MISAPPROPRIATE A TOTAL OF APPROXIMATELY $8,134 VIA ATM WITHDRAWALS FROM THE ACCOUNT. (CONTINUED IN THE COMMENTS SECTION)

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE HE WAS BARRED FROM ASSOCIATION WITH AN FINRA MEMBER IN ANY CAPACITY.