UNITED STATES SECURITIES AND EXCHANGE COMMISSION

   Investment Advisers Act of 1940
   Release No. 1807 / June 28, 1999

   Administrative Proceeding
   File No. 3-9922

   MPI INVESTMENT MANAGEMENT, DAVID PEQUET AND ASHOK SHENDE

   The Commission announced the entry of an Order Instituting Proceedings
   against MPI Investment Management (MPI), David Pequet (Pequet) and
   Ashok Shende (Shende).

   The Order alleges that in 1993 two partners decided to leave MPI which
   was, at the time, a partnership. However, MPI did not have funds
   available to satisfy the partnership interests of the departing
   partners. Accordingly, MPI entered into payment agreements with the
   former partners. By these agreements, MPI through the remaining
   partners, Pequet and Shende, agreed to pay them for their interests in
   MPI, in part, with $105,000 in directed commissions. In total, MPI
   directed over 100 trades of its clients to the former partners who
   received commissions for handling the trades. Between January 1994 and
   February 1996, MPI actually sent $73,043.89 in directed commissions to
   the two former partners.

   The trades which MPI directed to the former partners came primarily
   from the account of one large institutional client of MPI. This client
   was unaware of the agreements which MPI had reached with its former
   partners. MPI benefited from these agreements in that it did not need
   to pay the former partners with cash, but instead, could simply direct
   trades to compensate them.

   MPI did not disclose the arrangements with its former partners until
   August 1996. However, the large institutional client primarily used
   for generating commissions for the former partners, terminated its
   account with MPI in February of 1996, before any disclosure was made.
   Accordingly, MPI never disclosed the arrangements with its former
   partners to the client that was generating the directed commissions.

   The Order alleges that the failure to disclose the existence and
   material terms of the payment agreements with the former partners
   willfully violated Sections 206(1), 206 (2) and 207 of the Investment
   Advisers Act of 1940. The Order also alleges that Pequet and Shende
   aided and abetted the violations by negotiating the agreements, by
   executing documents, by either purposefully or recklessly failing to
   disclose these arrangements and by actually making the payments to the
   former partners. The Order goes on to allege that Pequet and Shende