UNITED STATES OF AMERICA
BEFORE THE
SECURITIES AND EXCHANGE COMMISSION
INVESTMENT ADVISERS ACT OF 1940
Release No. 1830 / September 22, 1999
ADMINISTRATIVE PROCEEDING
File No. 3-10023
In the Matter of
GARY L. PITTSFORD,
Respondent. ORDER INSTITUTING A PUBLIC ADMINISTRATIVE AND
CEASE-AND-DESIST PROCEEDING PURSUANT TO SECTIONS 203(f) AND 203(k) OF
THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING
SANCTIONS AND CEASE-AND-DESIST ORDER
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate and in the public interest that a public administrative
and cease-and-desist proceeding be and hereby is instituted pursuant
to Sections 203(f) and 203(k) of the Investment Advisers Act of 1940
("Advisers Act") against Gary L. Pittsford ("G.Pittsford").
II.
In anticipation of the institution of this proceeding, G.Pittsford has
submitted an Offer of Settlement which the Commission has determined
to accept. Solely for the purpose of this proceeding and any other
proceedings brought by or on behalf of the Commission or in which the
Commission is a party, and without admitting or denying the findings
contained herein, except the Commission's findings set forth in
paragraphs III. A. and III. B., which are admitted, G.Pittsford, by
his Offer of Settlement, consents to the entry of this Order
Instituting A Public Administrative and Cease-and-Desist Proceeding
Pursuant to Sections 203(f) and 203(k) of the Investment Advisers Act
of 1940, Making Findings, and Imposing Sanctions and Cease-and-Desist
Order ("Order").
Accordingly, IT IS HEREBY ORDERED that a proceeding pursuant to
Sections 203(f) and 203(k) of the Advisers Act be, and hereby is,
instituted.
III.
On the basis of this Order and the Offer of Settlement submitted by
G.Pittsford, the Commission makes the following findings
SNIPPETS:
UNITED STATES OF AMERICA BEFORE THE SECURITIES AND EXCHANGE COMMISSION
ADMINISTRATIVE PROCEEDING
THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING SANCTIONS AND
The Securities and Exchange Commission deems it appropriate and in the public interest that a
In anticipation of the institution of this proceeding, G.Pittsford has submitted an Offer of
Solely for the purpose of this proceeding and any other proceedings brought by or on behalf
and III. B., which are admitted, G.Pittsford, by his Offer of Settlement, consents to the
Accordingly, IT IS HEREBY ORDERED that a proceeding pursuant to Sections 203and 203of the
G.Pittsford, age 52, and a resident of Anderson, Indiana, has been the sole shareholder,
G.Pittsford has also been the president and one of two directors of Sulphur Implement
Pittsford provided investment management services on a discretionary basis to approximately
Pittsford withdrew its registration as an investment adviser, effective December 18, 1998.
This proceeding involves violative conduct of G.Pittsford, acting through his wholly-owned
SIC has raised approximately $4.4 million in a series of private placements of common stock
Almost all of this money has been raised from investment advisory clients of Pittsford.
Under the 1993 redemption agreement, G.Pittsford, Pittsford, and SIC agreed to jointly and
Between 1993 and the present, SIC made redemption payments of approximately $120,879 towards
Beginning in 1986 and continuing through the relevant period, Pittsford's quarterly
G.Pittsford caused and willfully aided and abetted Pittsford's violations of Sections 206and
N. During the relevant period, G.Pittsford willfully violated Section 207 of the Advisers Act
Such payments shall be made by United States postal money order, certified check, bank
Commission's case number, a copy of which cover letter and money order or check shall be sent to
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