Frederick J. Shapiro

SECURITIES EXCHANGE ACT OF 1934
Release No. 47831 / May 12, 2003

ADMINISTRATIVE PROCEEDING
File No. 3-11009

I.

The Securities and Exchange Commission ("Commission") deems it appropriate to accept the Offer of Settlement ("Offer") submitted by Jean B. Leclercq ("Leclercq") pursuant to Rule 240(a) of the Rules of Practice of the Commission, 17 C.F.R. § 201.240(a), for the purpose of settlement of this public administrative proceeding instituted by the Commission against her on January 14, 2003 pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act").

II.

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 herein, except as to the Commission's jurisdiction over her and over the subject matter of these proceedings, and the finding in Paragraph III.4. below, all of which are admitted, Leclercq consents to the entry by the Commission of this Order.

III.

On the basis of this Order and Leclercq's Offer, the Commission finds that:

1. During the period of October 2001 through May 2002, Leclercq was associated with Infinity Consulting Services, Inc. ("Infinity"), an unregistered broker-dealer, as its president and a sales agent.

2. On May 16, 2002, the Commission filed a complaint ("Complaint") in the United States District Court for the Southern District of Florida, Securities and Exchange Commission v. Starcash, Inc., et al., Case No. 02-80456-CIV-MIDDLEBROOKS/VITUNAC (S.D. Fla.). The Complaint charged Leclercq, among others, with violations of Sections 5(a), 5(c), and 17(a) of the Securities Act of 1933 ("Securities Act"), and Sections 10(b) and 15(a) of the Exchange Act and Rule 10b-5 thereunder.

3. The Commission's Complaint alleged that during the period of at least October 2001 until May 2002, in connection with the sale of securities, Leclercq falsely stated to investors, among other things, that their funds would be used to fund short-term payday advance loans to the public, and that the investment was virtually risk free and secured by the purported loans. The Complaint also alleged that Leclercq and others made baseless revenue predictions to investors. In addition, the Complaint alleged that Leclercq sold unregistered securities.

4. On September 23, 2002, based on the allegations in the Commission's Complaint, the District Court entered a judgment of permanent injunction and other relief by consent against Leclercq, permanently enjoining her from future violations of Sections 5(a), 5(c), and 17(a) of the Securities Act, and Sections 10(b) and 15(a) of the Exchange Act and Rule 10b-5 thereunder.

IV.

On the basis of the foregoing, the Commission deems it appropriate and in the public interest to accept Leclercq's Offer and impose the sanctions specified therein.

Accordingly, IT IS ORDERED that :

Pursuant to Section 15(b)(6) of the Exchange Act, Respondent Leclercq be, and hereby is barred from association with any broker or dealer as those terms are defined in the Exchange Act.

For the Commission, by its Secretary, pursuant to delegated authority.

Jonathan G. Katz
Secretary