UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 40489 / September 28, 1998 ADMINISTRATIVE PROCEEDING File No. 3-9736 ______________________________ : ORDER INSTITUTING PUBLIC In the Matter of : ADMINISTRATIVE PROCEEDINGS : PURSUANT TO SECTIONS 15(b) Patricia S. Gale, : AND 19(h) OF THE SECURITIES : EXCHANGE ACT OF 1934, : MAKING FINDINGS AND Respondent. : IMPOSING REMEDIAL SANCTIONS ______________________________: I. The Securities and Exchange Commission (Commission) deems it appropriate and in the public interest to institute administrative proceedings against Patricia S. Gale (Gale) pursuant to Sections 15(b) and 19(h) of the Securities Exchange Act of 1934 (Exchange Act). In anticipation of the institution of these administrative proceedings, Gale has submitted an Offer of Settlement (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 in which the Commission is a party, and without admitting or denying the findings contained herein, except those matters contained in subparagraphs III.(A) and (B) below, which are admitted, Gale, by her Offer, consents to the entry of this Order Instituting Proceedings, Making Findings and Imposing Remedial Sanctions. II. ACCORDINGLY, IT IS ORDERED that proceedings pursuant to Sections 15(b) and 19(h) of the Exchange Act be, and hereby are, instituted. III. On the basis of this Order and Gale's Offer, the Commission makes the following findings: A. During the period from in or about November 1989 to October 1990, Gale was a registered representative associated with a registered broker-dealer. B. On October 3, 1997, in the case of SEC v. Gary W. Berus, et al. (Civil Action File No. 96-74524), Judge Nancy G. Edmunds of the United States District Court for the Eastern District of Michigan, Southern Division, entered an Order of Permanent Injunction and Other Equitable Relief against Gale, pursuant to her consent and without admitting or denying the allegations contained in the Commission's Complaint, enjoining Gale from violating Section 17(a) of the Securities Act of 1933, Sections 10(b), 15(a)(1) and 15(c)(1) of the Exchange Act and Rules 10b-5 and 15c1-2 promulgated thereunder. C. The Commission's Complaint alleged that from approximately January 1990 to in or about April 1994, Gale, among others, participated in a scheme whereby approximately 120 investors were defrauded in connection with the offer, purchase and sale of over $3 million in fictitious certificates of deposit issued by a purported international bank, Century Security Bank & Trust, Ltd., and interests in two investment clubs, Profit Masters Group and Meca International, Inc. In connection therewith, Gale, directly and indirectly, made misrepresentations and omissions of material fact concerning the legitimacy of the investments, the returns to be expected, the commissions generated and the risks involved. The Commission's Complaint further alleged that by regularly offering and selling such securities for the account of others while also receiving commissions from such sales, Gale was acting as a securities broker and should have been registered as a broker-dealer with the Commission. IV. In view of the foregoing, it is in the public interest to impose the sanctions specified in the Offer. ACCORDINGLY, IT IS ORDERED THAT: Patricia S. Gale be, and hereby is, barred from association with any broker, dealer, municipal securities dealer, investment company or investment adviser. By the Commission. Jonathan G. Katz Secretary