UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES ACT OF 1933

Release No. 9217 / June 8, 2011

SECURITIES EXCHANGE ACT OF 1934

Release No. 64622 / June 8, 2011

ADMINISTRATIVE PROCEEDING

File No. 3-14163

In the Matter of

MMR INVESTMENT 

BANKERS, LLC (d/b/a MMR, 

INC.),

WILLIAM G. MARTIN, JR.,

EUGENE R. RANKIN,

JOHN A. HUBERT, and

 AARON D. FIMREITE,

Respondents.

ORDER MAKING FINDINGS AND 

IMPOSING REMEDIAL SANCTIONS AND A 

CEASE-AND-DESIST ORDER PURSUANT 

TO SECTION 8A OF THE SECURITIES ACT 

OF 1933 AND SECTIONS 15(b) AND 21C OF 

THE SECURITIES EXCHANGE ACT OF 

1934 AS TO RESPONDENT MMR 

INVESTMENT BANKERS, LLC (d/b/a MMR, 

INC.)

I.

On December 14, 2010, the Securities and Exchange Commission (“Commission”) 

instituted public administrative and cease-and-desist proceedings pursuant to Section 8A of the 

Securities Act of 1933 (“Securities Act”) and Sections 15(b) and 21C of the Securities Exchange 

Act of 1934 (“Exchange Act”) against Respondents MMR Investment Bankers, LLC , d/b/a MMR, 

Inc. (“MMR”); William G. Martin, Jr. (“Martin”); Eugene R. Rankin (“Rankin”); John A. Hubert

(“Hubert”); and Aaron D. Fimreite (“Fimreite”). 
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II.

In connection with these proceedings, Respondent MMR Investment Bankers, LLC (d/b/a 

MMR, Inc.) (“MMR” or “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 it and the subject matter of these proceedings and the facts stated in paragraphs 

III.1 through 5, which are admitted, Respondent MMR consents to the entry of this Order Making 

Findings and Imposing Remedial Sanctions and a Cease-and-Desist Order Pursuant to Section 8A 

of the Securities Act of 1933 and Sections 15(b) and 21C of the Securities Exchange Act of 1934 

as to Respondent MMR Investment Bankers, LLC (d/b/a MMR, Inc.) (“Order”), as set forth below. 

III.

On the basis of this Order and Respondent MMR’s Offer, the Commission finds1that: 

1. At all relevant times, Respondent MMR, located in Wichita, Kansas, was registered 

with the Commission as a broker-dealer. 

2. At all relevant times, Respondent Martin was the president and majority owner of 

MMR. He holds Series 7, 24, 27, 53, 63, and 79 licenses.

3. At all relevant times, Respondent Rankin was the vice-president and assistant 

compliance officer of MMR. He holds Series 7, 63 and 79 licenses. 

4. At all relevant times, Respondent Hubert was a registered representative associated 

with MMR. He holds Series 7, 63, and 79 licenses. 

5. At all relevant times, Respondent Fimreite was a registered representative 

associated with MMR. He holds Series 7, 63, and 79 licenses. 

6. From 2005 through 2008, Respondents recommended, offered, and sold eleven 

best-efforts, no minimum private placement debenture offerings for eight small start-up 

companies. 

 

1

 The findings herein are made pursuant to Respondent's Offer of Settlement 

and are not binding on any other person or entity in this or any other proceeding. 
3

7. The debenture companies were Dynamic Distribution, Inc.; El Pegasu 

Developmental, Inc.; Equity Capital Source, Inc.; Havoc Distribution, Inc.; MLP Associates, LLC

(“MLP”); Partners in Care; Southfield Energy Corp.; and Vending Ventures, Inc. 

8. All but one of the eight debenture companies are now in default on payments of 

interest and/or principal. 

9. Disclosure documents prepared by Respondents Martin and Rankin failed to 

disclose that Martin and Rankin created a new company, Sunflower Management Group, LLC 

(“Sunflower”), to manage the proceeds of the debenture sales; that Martin, Rankin, Fimreite, and 

Hubert’s wife all owned shares in Sunflower; that Sunflower received management fees in the 

amount of 1/12 of 1% of the total outstanding debentures, charged to the offering companies2; that 

in 2008, one of the offering companies, MLP, defaulted on maturing debentures from its 2005 

offering; or that Martin, Rankin, Hubert, and Fimreite had received shares in some of the offering 

companies pursuant to Sunflower’s management agreements with the companies. 

10. Respondent MMR, through Martin, Rankin, Hubert, and Fimreite, was reckless in 

not knowing of these material omissions. 

11. The debentures were unsuitable investments for numerous MMR customers given 

the level of risk in light of the customers’ investment objectives, advanced age, annual income, and 

net worth. Nevertheless, MMR through its registered representatives recommended and sold the 

debentures to numerous such customers. 

12. Respondent MMR, through Martin, Rankin, Hubert, and Fimreite, was reckless in 

not knowing that MMR was selling debentures to customers for whom the debentures were 

unsuitable investments. 

13. As a result of the conduct described above, Respondent MMR willfully violated 

Section 17(a) of the Securities Act and Section 10(b) of the Exchange Act and Rule 10b-5 

thereunder, which prohibit fraudulent conduct in the offer and sale of securities and in connection 

with the purchase or sale of securities.

14. As a result of the conduct described above, Respondent MMR willfully violated 

Section 15(c) of the Exchange Act, which similarly prohibits fraudulent conduct in the offer and 

sale of securities and in connection with the purchase or sale of securities by broker-dealers. 

 

2

In their disclosure documents for all but one of the offerings, Respondents did disclose 

the fact that a company affiliated with MMR received a management fee for managing the 

proceeds of the debenture sales, but did not disclose the amount of the fee. 
4

15. As a result of the conduct described above, Respondent MMR willfully violated 

Section 17(a) of the Exchange Act and Rule 17a-3(a)(17)(i)(B)(1) thereunder, which requires that 

customers receive an explanation of the terms regarding investment objectives. 

16. Respondent MMR has submitted a sworn Statement of Financial Condition dated 

January 28, 2011 and other evidence and has asserted its inability to pay a civil penalty.

IV.

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

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

Accordingly, pursuant to Section 8A of the Securities Act and Sections 15(b) and 21C of 

the Exchange Act, it is hereby ORDERED that:

A. Respondent MMR shall cease and desist from committing or causing any violations 

and any future violations of Section 17(a) of the Securities Act, Sections 10(b) and 15(c) of the 

Exchange Act, and Rules 10b-5 and 17a-3(a)(17)(i)(B)(1) thereunder, 

B. Respondent MMR shall be censured. 

C. MMR’s broker-dealer registration with the Commission shall be, and is, revoked. 

D. Any reapplication for registration by Respondent MMR 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, the satisfaction of any or all of the 

following: (a) any disgorgement ordered against the Respondent, whether or not the Commission 

has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the 

conduct that served as the basis for the Commission order; (c) 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 (d) any restitution order by a self-regulatory organization, whether or 

not related to the conduct that served as the basis for the Commission order,

E. Based upon Respondent's sworn representations in its Statement of Financial 

Condition dated January 28, 2011 and other documents submitted to the Commission, the 

Commission is not imposing a penalty against Respondent.

By the Commission.

Elizabeth M. Murphy
5

Secretary
6

Service List

Rule 141 of the Commission's Rules of Practice provides that the Secretary, or another duly 

authorized officer of the Commission, shall serve a copy of the Order Making Findings and 

Imposing Remedial Sanctions and a Cease-and-Desist Order Pursuant to Section 8A of the 

Securities Act of 1933 and Sections 15(b) and 21C of the Securities Exchange Act of 1934 as to 

Respondent MMR Investment Bankers, LLC (d/b/a MMR, Inc.) ("Order"), on the Respondent and 

its legal agent.

The attached Order has been sent to the following parties and other persons entitled to 

notice:

Honorable Brenda P. Murray

Chief Administrative Law Judge

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549-2557

Polly Atkinson, Esq.

Denver Regional Office

Securities and Exchange Commission 

1801 California Street

Suite 1500

Denver, CO 80202

MMR Investment Bankers, LLC (d/b/a MMR, Inc.)

c/o Philip Bledsoe, Esq. 

Polsinelli Shughart

1050 17th Street

Suite 2300

Denver, CO 80265 

Philip Bledsoe, Esq. 

Polsinelli Shughart

1050 17th Street

Suite 2300

Denver, CO 80265 

(Counsel for MMR Investment Bankers, LLC (d/b/a MMR, Inc.))