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1
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SEC ADMINISTRATIVE PROCEEDING
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EXTRACTED KEY WORDS
SULLIVAN ACT REGISTRANT ADVISERS ACT TRADING VIOLATION PORTFOLIO MANAGERS COMMISSION DERIVATIVES LIMITS OVERLAY ORDER TICKETS OVERLAY PROGRAM TRADES PURSUANT ACCOUNTS THEREUNDER IMPOSE SECURITIES INSTITUTING FINDINGS UNAUTHORIZED TRADING EXECUTE TRANSACTIONS SALES MISCODING PARTICIPATING RISK PURCHASES |
UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
INVESTMENT ADVISERS ACT OF 1940
Release No. 1849 / December 22, 1999
INVESTMENT COMPANY ACT OF 1940
Release No. 24219 / December 22, 1999
ADMINISTRATIVE PROCEEDING
File No. 3-10122
In the Matter of
MICHAEL T. SULLIVAN, III
Respondent.
ORDER INSTITUTING PROCEEDINGS,
MAKING FINDINGS, IMPOSING
REMEDIAL SANCTIONS AND
CEASE-AND-DESIST ORDER
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate and in the public interest that public administrative and
cease-and-desist proceedings be, and hereby are, instituted pursuant
to Sections 203(f) and 203(k) of the Investment Advisers Act of 1940
(the "Advisers Act") and Sections 9(b) and 9(f) of the Investment
Company Act of 1940 (the "Investment Company Act") against Michael T.
Sullivan, III ("Sullivan").
II.
In anticipation of the institution of these administrative
proceedings, Sullivan has submitted an Offer of Settlement ("Offer"),
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 in which the Commission is a party, and
without admitting or denying any of the findings contained herein,
except those findings pertaining to the jurisdiction of the Commission
over him and over the subject matter of these proceedings, which he
admits, Sullivan consents to the entry of this Order Instituting
Proceedings, Making Findings, Imposing Remedial Sanctions and
Cease-and-Desist Order ("Order").
SNIPPETS:
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