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AUGUSTA, MAINE  04333-0121



_______________________________________                                                                                                                                                                                  )                                             

IN THE MATTER OF:                                                  )


Summit Brokerage Services, Inc.                              )            CONSENT AGREEMENT

980 N. Federal Highway, Suite 310                           )                   No. 04-024-CAG

Boca Raton, FL  33432                                               )





            This Agreement is entered into between the State of Maine Office of Securities (“Office of Securities”) and Summit Brokerage Services, Inc. (“Summit”), CRD #34643,

a broker-dealer located in Baca Raton, FL  33432.


            WHEREAS, the parties agree as follows:


1.            At all relevant times, it has been unlawful in Maine for a person to act as a broker-dealer unless licensed or exempt from licensing under the Revised Maine Securities Act, Title 32 Maine Revised Statutes Annotated § 10101 et seq.


2.            Summit filed an application with the Office of Securities for licensing as a broker-dealer on March 12, 2001;


3.            On March 18, 2001, the Office of Securities sent a letter to Summit’s clearing firm, First Clearing Corporation (“First Clearing”), requesting that First Clearing review its records to determine whether any of Summit’s principals, sales representatives, or affiliates had engaged in securities transactions with Maine residents within the last six years.


4.            On April 18, 2001, the Office of Securities sent a letter to Summit requesting that the firm provide additional information in connection with its pending broker-dealer application.





5.            In response to the March 18, 2001, letter, First Clearing informed the Office of Securities in correspondence dated April 30, 2001, that Summit had effected at least thirteen (13) transactions for the accounts of three Maine clients while unlicensed. 


6.            On August 12, 2003, Summit’s Chief Compliance Officer called the Office of Securities to check on the status of its application, which had been dormant since April of 2001.


7.            On August 12, 2003, the Office of Securities sent a follow-up letter to Summit requesting that the firm provide information in connection with its pending broker-dealer application, including information concerning its unlicensed activity in Maine.


8.            Between August 22, 2003, and November 21, 2003, Summit provided the Office of Securities with the requested information concerning the firm, as well as its unlicensed activity in Maine.


9.            It is the Office of Securities’ position that Summit has acted as a broker-dealer in Maine without being licensed or exempt from licensing.


10.       Summit has represented to the Office of Securities that the violations were unintentional.


11.       Both parties desire an expeditious resolution of this matter.



NOW, THEREFORE, without trial or adjudication of any issue of fact or law, and without Summit admitting or denying that its conduct violated the Revised Maine Securities Act, it is agreed that:


1.            Summit will comply with all licensing and other legal requirements governing persons acting as securities broker-dealers in the State of Maine at all times from the date hereof.


2.            In lieu of the Office of Securities seeking the imposition of a penalty for the allegations contained herein, Summit will pay the sum of $4,632.23 to the Office of Securities upon Summit’s execution of this Agreement.


3.            The Office of Securities will not take further action against Summit, based upon its unlicensed status during the period preceding and including the date of execution of this Agreement, PROVIDED, however, that this paragraph applies only to those transactions previously disclosed to the Office of Securities by Summit.




December 8, 2003                                       /s/ Marshall T. Leeds, President, CEO

Date                                                                Marshall T. Leeds, President, CEO

                                                                        Summit Brokerage Services, Inc.




December 9, 2003                                       /s/ Christine A. Bruenn         

Date                                                                Christine A. Bruenn

                                                                        Securities Administrator


Reviewed by:




December 9, 2003                                       /s/ Bonnie E. Russell

Date                                                                Bonnie E. Russell

                                                                        Assistant Securities Administrator


Presented by:




December 9, 2003                                       /s/ Cathy J. Williams

Date                                                                Cathy J. Williams

                                                                        Licensing Coordinator