UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934
Release No. 41899 / September 22, 1999

   ADMINISTRATIVE PROCEEDING
   FILE NO. 3-9840
   ______________________________
   In the Matter of               ORDER MAKING FINDINGS
                                  AND IMPOSING REMEDIAL SANCTIONS
   Robin A. Heiney
   ______________________________
   I.

   On March 3, 1999, the Securities and Exchange Commission
   ("Commission") issued an Order Instituting a Public Proceeding
   Pursuant to Sections 15(b)(6) and 19(h) of the Securities Exchange Act
   of 1934 ("Exchange Act") against Robin A. Heiney ("Heiney").

   Heiney has submitted to the Commission an Offer of Settlement 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 to which the Commission is a party and without
   admitting or denying the findings, except those contained in
   paragraphs II(A) and (B) below, which are admitted, Heiney consents to
   the entry of this Order Making Findings and Imposing Remedial
   Sanctions ("Order").

   II.

   On the basis of this Order and the Offer of Settlement submitted by
   Heiney, the Commission finds that

   A. From approximately August 1989 to April 1990, Heiney was associated
   as a registered representative with Brennan Ross Securities, Inc.
   ("Brennan Ross"). From May 1990 through August 1990, he was associated
   as a registered representative of National Securities Corp.
   ("National"). Brennan Ross and National were, at all relevant times,
   broker-dealers registered with the Commission.

   B. On January 18, 1995, Heiney was convicted, on his plea of guilty,
   of one count of securities fraud. United States v. Robin A. Heiney,
   Case No. 94-CR-339-S (D. Colo. 1995).

   C. In his plea agreement, Heiney admitted that he was paid undisclosed
   compensation, totaling approximately $13,249, for promoting and