Stephan Peter Boruchin (CRD #1201115, Registered Principal, Edmond, Oklahoma) submitted a Letter of Acceptance, Waiver and Consent in which he was barred from association with any NASD member in any capacity. Without admitting or denying the findings, Boruchin consented to the described sanction and to the entry of findings that he provided, or caused to be provided, false information to NASD regarding a $300,000 deposit into his member firm’s clearing account. The findings stated that Boruchin failed to respond to NASD requests for documents and to appear and provide testimony. The findings also stated that Boruchin improperly used the market maker exemption contained in NASD Rule 3370 to avoid compliance with the affirmative determination rule, in that he used the market maker exemption while engaging in speculative proprietary trading, including short sales, rather than bona fide market making activity. (NASD Case #2005000879301)