UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 99903 / April 3, 2024

ADMINISTRATIVE PROCEEDING

File No. 3-21901

In the Matter of

RONALD M. HEINEMAN, 

Respondent.

ORDER INSTITUTING 

ADMINISTRATIVE PROCEEDINGS 

PURSUANT TO SECTION 15(b) OF THE 

SECURITIES EXCHANGE ACT OF 1934, 

MAKING FINDINGS, AND IMPOSING 

REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission (“Commission”) deems it appropriate and in the 

public interest that public administrative proceedings be, and hereby are, instituted pursuant to 

Section 15(b) of the Securities Exchange Act of 1934 (“Exchange Act”) against Ronald M. 

Heineman (“Respondent”). 

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer 

of Settlement (the “Offer”) which the Commission has determined to accept. Solely for the 

purpose of these proceedings and any other proceedings brought by or on behalf of the 

Commission, or to which the Commission is a party, and without admitting or denying the findings 

herein, except as to the Commission’s jurisdiction over him and the subject matter of these 

proceedings and the findings contained in paragraph III.2 below, which are admitted, Respondent

consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Section 15(b) 

of the Securities Exchange Act of 1934, Making Findings, and Imposing Remedial Sanctions

(“Order”), as set forth below. 
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III.

On the basis of this Order and Respondent’s Offer, the Commission finds that:

1. Heineman, 79 years old, is a resident of Roseland, New Jersey. Heineman was the 

principal and chief compliance officer of Halcyon Cabot Partners, Ltd. (“Halcyon”), a brokerdealer formerly registered with the Commission, from 2010 to 2013. Prior to co-founding Halcyon, 

he was associated with a number of other registered broker-dealers prior to that starting in 1981.

2. On April 1, 2024, a final judgment was entered by consent against Heineman, 

permanently enjoining him from future violations of Section 17(a) of the Securities Act of 1933 

and Sections 9(a) and 10(b) of the Exchange Act and Rule 10b-5 thereunder, in the civil action 

entitled Securities and Exchange Commission v. DiScala, et al., 14-cv-4346 (ENV), in the United 

States District Court for the Eastern District of New York. 

3. The Commission’s complaint alleged that in 2013, as chief compliance officer of 

Halcyon, Heineman ignored red flags related to trading in CodeSmart and the conduct of one of 

Halcyon’s registered representatives, as well as that he engaged in a scheme to manipulate the 

price of the stock of CodeSmart Holdings, Inc. by engaging in matched trading. 

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to 

impose the sanctions agreed to in Respondent Heineman’s Offer.

Accordingly, it is hereby ORDERED pursuant to Section 15(b)(6) of the Exchange Act, 

that Respondent Heineman be, and hereby is barred from association with any broker, dealer, 

investment adviser, municipal securities dealer, municipal advisor, transfer agent, or nationally 

recognized statistical rating organization.
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Any reapplication for association by the Respondent will be subject to the applicable laws 

and regulations governing the reentry process, and reentry may be conditioned upon a number of 

factors, including, but not limited to, compliance with the Commission’s order and payment of any 

or all of the following: (a) any disgorgement or civil penalties ordered by a Court against the 

Respondent in any action brought by the Commission; (b) any disgorgement amounts ordered 

against the Respondent for which the Commission waived payment; (c) any arbitration award 

related to the conduct that served as the basis for the Commission order; (d) any self-regulatory 

organization arbitration award to a customer, whether or not related to the conduct that served as 

the basis for the Commission order; and (e) any restitution order by a self-regulatory organization, 

whether or not related to the conduct that served as the basis for the Commission order.

By the Commission.

Vanessa A. Countryman

Secretary