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SEC ADMINISTRATIVE PROCEEDING
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EXTRACTED KEY WORDS
INVESTMENT ADVISERS FORM ADV-Y2K VAN CLEEF ASSET MANAGEMENT EXCHANGE COMMISSION INVESTMENT ADVISERS ACT APODACA INVESTMENT GROUP BROWER FINANCIAL SERVICES RONALD ALLAN MCDOW ALLEGES REPORTED ASSETS SECURITIES ADMINISTRATIVE PROCEEDING ADVISORS INVESTMENT COMPANY RESPONDENTS MINNESOTA NASHVILLE TENNESSEE BEACHWOOD OHIO LEXINGTON KENTUCKY PREPAREDNESS ENFORCEMENT ALLEGATIONS CIVIL PENALTIES SANCTIONS |
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Investment Advisers Act of 1940
Release No. 1800 \ May 4, 1999
Administrative Proceeding
File No. 3-9888
In the Matter of Apodaca Investment Group, Inc., Brower Financial
Services, Inc., Ethical Investments, Inc., Ronald Allan McDow, Van
Cleef Asset Management, Inc., and WWW Advisors, Inc.
The Securities and Exchange Commission ("Commission") instituted a
cease-and-desist and administrative proceeding against six investment
advisers for failing to timely file Form ADV-Y2K. The advisers are
Apodaca Investment Group, Inc. ("Apodaca") of San Francisco,
California; Brower Financial Services, Inc. ("Brower") of Salt Lake
City, Utah; Ethical Investments, Inc. ("Ethical") of Minneapolis,
Minnesota; Ronald Allan McDow ("McDow") of Nashville, Tennessee; Van
Cleef Asset Management, Inc. ("Van Cleef") of Beachwood, Ohio; and WWW
Advisors, Inc. ("WWW") of Lexington, Kentucky. Form ADV-Y2K was
designed to enable the Commission to evaluate the preparedness of
investment advisers for the Year 2000. In the Order, the Division of
Enforcement ("Division") alleges that Apodaca, Brower, McDow and Van
Cleef, each of which reported assets under management of not less than
$25 million, were required to and failed to file Part I of Form
ADV-Y2K by December 7, 1998. The Division further alleges that Ethical
and WWW failed to file Parts I and II of Form ADV-Y2K by December 7,
1998. Ethical and WWW were required to file both Parts I and II of
Form ADV-Y2K because each reported that it advised an investment
company registered under the Investment Company Act of 1940. Ethical
also reported assets under management of not less than $25 million.
The Order alleges that the respondents willfully violated Section 204
of the Investment Advisers Act of 1940 and Rule 204-5.
A hearing will be scheduled to determine whether the allegations are
true and whether cease-and-desist orders, civil penalties and other
sanctions are appropriate against these respondents.
_________________________________________________________________
Modified 05/04/1999
SNIPPETS:
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