Selling Away and Outside Business Activity FINRA Arbitration and Litigation Attorney, Russell L. Forkey, Esq.

February, 2012:

In the Matter of Robert C. Koeller

Recently, the Securities and Exchange Commission (SEC) issued an Order Instituting Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange Act of 1934, Making Findings and Imposing Remedial Sanctions (Order) against Robert C. Koeller. The Order is based on the entry of a permanent injunction against Koeller in United States Securities and Exchange Commission v. Steven R. Long, et al., Civil Action No. 1:10cv00782 (N.D. Ohio), enjoining him from violating the securities registration, anti-fraud, and broker registration provisions of the federal securities laws. The Commission’s complaint in that litigation alleged that Koeller offered and sold unregistered securities in the form of promissory notes purportedly secured by real estate and that he made multiple fraudulent misrepresentations and omissions in connection with those offerings and sales. The complaint also alleged that Koeller acted as an unregistered broker.

Koeller consented to issuance of the Order, without admitting or denying the Commission’s findings, except as to the entry of the final judgment, which he admitted. The Order bars Koeller from association with any broker, dealer, investment adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally recognized statistical rating organization, and from participating in any offering of a penny stock, with the right to apply for reentry after five years.