Bruce Libman

an Offer of Settlement in which he was barred from association with any FINRA member in any capacity. Without admitting or denying the allegations, Libman consented to the described sanction and to the entry of findings that he invested funds a friend provided in a private securities transaction pursuant to a participation agreement with the company and failed to notify his member firm in writing and obtain its approval prior to making the investment. Libman received compensation from the company as a result of the private securities transaction. The findings stated that FINRA requested that Libman provide, among other things, all records for all bank accounts and financial accounts in which he had an interest. In response, Libman produced certain monthly statements and copies of certain checks drawn from his accounts, but failed to provide any copies of checks deposited into the accounts. The findings also stated that FINRA requested additional information pertaining to Libman’s deposits and specifically pertaining to the deposit of $202,673.58, to include the identity of the person or the entity providing the funds and the purpose for which the funds were provided to Libman. FINRA also requested that Libman identify each deposit that included funds obtained directly or indirectly from his friend.  The findings also included that Libman, through his counsel, refused to provide FINRA the requested bank documents and information relating to the bank deposits. Libman’s counsel also informed FINRA that Libman would no longer cooperate with the investigation. (FINRA Case #2009016911206).