UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

   INVESTMENT ADVISERS ACT OF 1940
   Rel. No. 1844 / November 1, 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.

   Respondents.

   ORDER MAKING FINDINGS,
   ISSUING CEASE-AND-DESIST ORDERS,
   AND IMPOSING CIVIL PENALTIES
   AGAINST APODACA INVESTMENT GROUP, INC. AND VAN CLEEF ASSET MANAGEMENT,
   INC.

   I.

   The Securities and Exchange Commission ("Commission") has previously
   instituted an administrative and cease-and-desist proceeding against
   Apodaca Investment Group, Inc. ("Apodaca") and Van Cleef Asset
   Management, Inc. ("Van Cleef") pursuant to Sections 203(e) and 203(k)
   of the Investment Advisers Act of 1940 ("Advisers Act").

   II.

   Apodaca and Van Cleef have submitted Offers of Settlement for the
   purpose of disposing of the issues raised by this proceeding. Solely
   for the purposes of this proceeding and any other proceeding brought
   by or on behalf of the Commission or to which the Commission is a
   party, and prior to a hearing and without admitting or denying the
   findings set forth herein, except that Apodaca and Van Cleef each
   admits the jurisdiction of the Commission over each of them and over
   the subject matter of this proceeding, Apodaca and Van Cleef each
   consent to the entry of this Order Making Findings, Issuing
   Cease-and-Desist Orders and Imposing Civil Penalties Against Apodaca
   Investment Group, Inc. and Van Cleef Asset Management, Inc. ("Order").
   The Commission has determined that it is appropriate in the public