UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

   SECURITIES EXCHANGE ACT OF 1934
   Release No. 41485 / June 7, 1999

   ADMINISTRATIVE PROCEEDING
   File No. 3-9080

   In the Matter of

   RAUL N. RODRIGUEZ
   ORDER REINSTATING ATTORNEY
   UNDER RULE 102(e)(5) OF
   THE COMMISSION'S RULES OF PRACTICE

   I.

   On September 16, 1996, the Commission, pursuant to Rule 102(e)(3) of
   the Commission's Rules of Practice, suspended attorney Raul N.
   Rodriguez from appearing or practicing before the Commission, with the
   right to apply for reinstatement after two years. See Opinion and
   Order, Release No. 37682 (Sept. 16, 1996). The basis for the
   suspension was an action by the Commission in which the United States
   District Court for the Southern District of New York found that
   Rodriguez knowingly or recklessly drafted, reviewed, or signed
   materially false and misleading documents filed with the Commission.

   The Opinion and Order provided that for reinstatement, Rodriguez would
   have to submit an affidavit truthfully stating under penalty of
   perjury that (1) he had complied with the Opinion and Order, (2) that
   he is not subject to any suspension or disbarment as an attorney by a
   court of the United States or any state, territory, district,
   commonwealth or possession, and (3) that he has not been convicted of
   a felony or of a misdemeanor involving moral turpitude.

   II.

   On December 17, 1998, over two years after he had been suspended by
   the Commission, Rodriguez applied for reinstatement to appear or
   practice before the Commission. His application included an affidavit
   in which he swore under penalty of perjury that he had complied with
   Commission's Opinion and Order, that he was not subject to suspension
   or disbarment by any court, and that he had not been convicted of a
   felony or of a misdemeanor involving moral turpitude.

   III.