A broker with RBC Capital Markets accepted substantial FINRA sanctions to settle charges he marked the market in an OTC Bulletin Board stock.  Victor Topper, 41, a broker since 1992, was working out of the Dallas, TX, office when in 2007 he allegedly transmitted buy orders to the trading desk on his customer’s behalf at the end of consecutive trading dates. FINRA Market Regulation Investigation. Topper's trading was picked up by the Market Manipulation Investigation staff in Market Regulation, which was investigating trading activities in BlueFire Ethanol Fuels, Inc. ("BFRE"), an OTCBB stock, during the trading dates from 9/26/07 through 10/2/07. They found that Topper transmitted customer buy orders at the end of 4 of 5 consecutive trading sessions, each time influencing the closing bid price of $5.01 in the stock.  Topper was out of the office on the 5th trading day, but he had his co-workers look out for the order and process it - which they did exactly the same way. By establishing a closing inside bid price of $5.01, Topper facilitated the appearance of compliance with listing standards for potential listing of BFRE on the Nasdaq Stock Market. Day One - 9/26/07. At 3:58, Topper received a customer's limit order to buy 10,000 shares of BFRE up to a bid of $5.01 per share.  One minute the order was sent to the trading desk, even though the then-current NBBO for the stock was $4.90 and $4.95. The RBC's trading desk entered the order as a market order, resulting in the execution of  2,500 shares at the price of $5.12 per share, leaving 7,500 shares unexecuted.  Although the inside bid price was only $4.90 at the time Topper transmitted the customer order to the firm's trading desk, as a result of the order the inside bid closed at a price of $5.01. Day Two - 9/27/07. At about 3:42 p.m., 18 minutes before the close, Topper received an order to purchase 10,000 shares of BFRE from the customer up to a bid price of $5.01 per share. Topper immediately transmitted the order to the firm's trading desk, even though the then NBBO was $4.81 and $4.90, respectively. A few minutes later, at about 3:54 p.m., the customer instructed Topper to purchase an additional 25,000 shares at $5.01.  The orders went to the trading desk and 17,000 shares were purchased at an average price of $4.97, leaving 18,000 shares unexecuted.  Once again, as a result of the order, the inside bid closed at $5.01. Similar Scenarios on 9/28, 10/1, 10/2.   Similar scenarios, each having the identical impact on the closing inside bid, occurred on these days, as well. FINRA Sanctions. Topper accepted a $20K fine and a 180-day suspension.  For further details, go to:   [FINRA AWC #2008012624201].   [Disciplinary Action for October 2011.]