FINRA

WILLFULLY VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934, RULE 10B-5 THEREUNDER, VIOLATED SECTION 5 OF THE SECURITIES ACT OF 1933, FINRA RULES 2010, 2020, 2150(A), 4511, 8210, NASD RULES 3040,3110 - FREDERICK BRIMMER MISAPPROPRIATED $10,000 FROM TWO ELDERLY BROKERAGE CUSTOMERS BY DEPOSITING THEIR FUNDS INTO HIS PERSONAL BANK ACCOUNT. THE CUSTOMERS HAD PROVIDED BRIMMER WITH THE MONEY FOR A SUPPOSED INVESTMENT IN AN AUTO BROKER SALES BUSINESS. RATHER THAN INVEST THE MONEY ON THE CUSTOMERS' BEHALF, BRIMMER DEPOSITED THE MONEY INTO HIS PERSONAL BANK ACCOUNT AND THE CUSTOMERS NEVER RECEIVED ANY MONEY BACK OR RETURNS FROM BRIMMER. BRIMMER INTENTIONALLY AND RECKLESSLY OMITTED MATERIAL FACTS IN CONNECTION WITH HIS SOLICITATION OF ELDERLY BROKERAGE CUSTOMERS. THE MATERIAL OMISSIONS CONSISTED OF FAILING TO DISCLOSE TO EACH CUSTOMER THAT BRIMMER ANTICIPATED RECEIVING A REFERRAL FEE TOTALING $30,000 FOR INTRODUCING THE BROKERAGE CUSTOMERS TO AN INDIVIDUAL, WHO ENTERED INTO PROMISSORY NOTES WITH EACH CUSTOMER AND COMMITTED TO REPAY THE CUSTOMERS' PRINCIPAL INVESTMENT (COLLECTIVELY TOTALING $150,000) PLUS RETURNS OF 200% WITHIN MATURITY DATES OF ABOUT A MONTH OF THE EXECUTION OF THE PROMISSORY NOTES. NONE OF THE CUSTOMERS RECEIVED ANY OF THEIR PRINCIPAL OR PROMISED INTEREST AS OF THE MATURITY DATE OF THE PROMISSORY NOTES. BRIMMER FAILED TO PROVIDE HIS MEMBER FIRM WRITTEN NOTICE PRIOR TO HIS INVOLVEMENT IN PRIVATE SECURITIES TRANSACTIONS IN CONNECTION WITH PRIVATE SECURITIES TRANSACTIONS ASSOCIATED WITH THE INDIVIDUAL AND A PRIVATE PLACEMENT BOND ISSUE INVOLVING A POOLED VENTURE TO FACILITATE FINANCING FOR THE ESTABLISHMENT OF A BUSINESS. THE ELDERLY CUSTOMERS INVESTED A TOTAL OF APPROXIMATELY $420,000 IN EITHER THE PROMISSORY NOTES OR THE BOND ISSUE. BRIMMER SOLD, OR OFFERED TO SELL, UNREGISTERED SECURITIES IN CONNECTION WITH THE PRIVATE SECURITIES TRANSACTIONS. NEITHER A REGISTRATION STATEMENT NOR A FORM D FILING CLAIMING ANY EXEMPTION EXISTED ON FILE WITH THE SEC. BRIMMER MAINTAINED COMMUNICATIONS AND OTHER RECORDS OF HIS INVESTMENT ACTIVITIES VIA PERSONAL EMAIL AND PERSONAL COMPUTER STORAGE ACCOUNTS THAT WERE UNCONNECTED TO HIS THEN MEMBER FIRM'S COMPUTER NETWORK IN VIOLATION OF FINRA'S BOOKS AND RECORDS REQUIREMENTS. IN CONNECTION WITH FINRA'S INVESTIGATION OF THIS MATTER, BRIMMER PROVIDED FALSE AND INCOMPLETE TESTIMONY ABOUT MULTIPLE FACTUAL POINTS.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

Indefinite

9/28/2012

WITHOUT ADMITTING OR DENYING THE FINDINGS, BRIMMER CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS BARRED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY. THIS SETTLEMENT INCLUDES A FINDING THAT BRIMMER WILLFULLY VIOLATED SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER. PURSUANT TO ARTICLE III, SECTION 4 OF FINRA'S BY-LAWS, THIS MAKES BRIMMER SUBJECT TO A STATUTORY DISQUALIFICATION WITH RESPECT TO ASSOCIATION WITH A MEMBER.