UNITED STATES OF AMERICA
before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES ACT OF 1933
Release No. 8034 / November 15, 2001
SECURITIES EXCHANGE ACT OF 1934
Release No. 45064 / November 15, 2001
INVESTMENT ADVISERS ACT OF 1940
Release No. 1996 / November 15, 2001
INVESTMENT COMPANY ACT OF 1940
Release No. 25268 / November 15, 2001
ADMINISTRATIVE PROCEEDING
File No. 3-10253
_________________________________________________________________
In the Matter of
Vector Index Advisors, Inc.
and Steven H. Adler,
Respondents.
_________________________________________________________________
ORDER MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AND
CEASE-AND-DESIST ORDER PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF
1933, SECTIONS 15(b)(6), 19(h) AND 21C OF THE SECURITIES EXCHANGE ACT
OF 1934, SECTIONS 203(f) AND 203(k) OF THE INVESTMENT ADVISERS ACT OF
1940, AND SECTION 9(b) OF THE INVESTMENT COMPANY ACT OF 1940 AS TO
STEVEN H. ADLER
I.
On July 18, 2000, the Securities and Exchange Commission
("Commission") entered an Order Instituting Public Administrative and
Cease-and-Desist Proceedings Pursuant to Section 8A of the Securities
Act of 1933 ("Securities Act"), Sections 15(b)(6), 19(h), and 21C of
the Securities Exchange Act of 1934 ("Exchange Act"), Sections 203(f)
and 203(k) of the Investment Advisers Act of 1940 ("Advisers Act"),
and Section 9(b) of the Investment Company Act of 1940 ("Investment
Company Act") against Steven H. Adler and Vector Index Advisors, Inc.
II.
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
INVESTMENT ADVISERS ACT OF 1940
Vector Index Advisors, Inc. and Steven H. Adler,
ORDER MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AND CEASE-AND-DESIST ORDER PURSUANT TO
1933, SECTIONS 15, 19AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, SECTIONS 203AND 203OF
Respondent Steven H. Adler has submitted an Offer of Settlement for the purpose of resolving
Solely for the purpose of these proceedings and any other proceedings brought by or on behalf
Vector, incorporated in Florida in 1990, was an investment adviser registered with the
Commencing on February 1, 1991, Vector provided investment advisory services to ASM, a mutual
From October 1994 through September 1998, Adler offered and sold to 11 investors, who became
Under the timing program, Adler would purportedly transfer the clients' funds between ASM, in
In fact, Adler never operated the timing program; instead, Adler and Vector misappropriated
During the relevant period, Adler prepared and sent letters on Vector and ASM stationery to
Adler provided each client with calculations showing the initial net asset value of the ASM
Adler knew that these valuations were false, as no investor funds were actually used to
Contrary to Adler's representations to the clients, and contrary to the information that he
As a result of the conduct described above, Adler willfully aided and abetted and caused
Adler aided and abetted and caused Vector to fail to maintain a true, accurate or current
Respondent has submitted a sworn Statement of Financial Condition, dated June 26, 2001, and
In view of the foregoing, the Commission deems it appropriate, in the public interest, and
In connection with any such petition, the only issues shall be whether the financial
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