Von Christopher Cummings, John A. Ryan, Kevin L. Grandy, James Curtis Conley, Michael L. Vogt, John E. Hawley, Jr.

Securities Exchange Act of 1934
Release No. 50544 / October 14, 2004

Investment Advisers Act of 1940
Release No. 2314 / October 14, 2004

Admin. Proc. File No. 3-11709

In the Matter of Von Christopher Cummings, John A. Ryan, Kevin L. Grandy, James Curtis Conley, Michael L. Vogt, John E. Hawley, Jr., Respondents.

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ORDER INSTITUTING ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 15(b) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(f) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 15(b) of the Securities Exchange Act of 1934 ("Exchange Act") against Respondents James Curtis Conley ("Conley"), Michael L. Vogt ("Vogt") and John E. Hawley, Jr. ("Hawley") and Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act") against Respondents Von Christopher Cummings ("Cummings"), John A. Ryan ("Ryan"), Kevin L. Grandy ("Grandy") and Conley (collectively Cummings, Ryan, Grandy, Conley, Vogt and Hawley are referred to as "Respondents").

II.

In anticipation of the institution of these proceedings, Respondents have submitted Offers of Settlement (the "Offers") 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 to which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over them and the subject matter of these proceedings, and the findings contained in Section III.A(2) with respect to Cummings, Section III.B(2) with respect to Ryan, Section III.C(2) with respect to Grandy, Section III.D(2) with respect to Conley, Section III.E(2) with respect to Vogt and Section III.F(2) with respect to Hawley, which are admitted, Respondents consent to the entry of this Order Instituting Administrative Proceedings Pursuant to Section 15(b) of the Securities Exchange Act of 1934 and Section 203(f) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions ("Order"), as set forth below.

III.

A. Cummings

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

1. Cummings held himself out as an investment adviser and represented Paramount Financial Partners, L.P. ("Paramount Financial") as a registered investment adviser when he solicited and induced clients and other associates to invest. Cummings claimed to investors that Paramount Financial was a hedge fund that generated large returns for clients. Paramount Financial and Cummings were not registered with the Commission as investment advisers. Cummings is licensed by the National Association of Securities Dealers (NASD). Cummings, age 34, resides in Dublin, Ohio.

2. On September 27, 2004, a final judgment was entered by consent against Cummings, permanently enjoining him from future violations of Section 17(a) of the Securities Act of 1933 ("Securities Act"), Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled Securities and Exchange Commission v. Von Christopher Cummings, et al., Civil Action Number C2-02-629, in the United States District Court for the Southern District of Ohio ("SEC v. Cummings, et al.").

3. The Commission's complaint alleged that Cummings solicited and induced clients to participate in Paramount Financial investments. Cummings claimed to be a registered investment adviser in order to further Paramount Financial's activities. Cummings and Paramount Financial were not registered with the Commission as investment advisers. Cummings did not invest the investors' funds as promised.

B. Ryan

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

1. Between January 1, 2001 and July 5, 2001, Ryan was associated with Paramount Financial, a purported hedge fund that was falsely represented to investors as generating large returns for clients. Unbeknownst to Ryan at the time, Paramount Financial was in fact not a hedge fund and did not buy or sell securities for clients' accounts. Ryan, however, at the direction of Cummings, acted as an unregistered investment adviser that used investor funds to repay prior investors and for personal and business expenses.

2. On September 27, 2004, a final judgment was entered by consent against Ryan, permanently enjoining him from future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled SEC v. Cummings, et al.

3. The Commission's complaint alleged, among other things, that Ryan solicited and induced clients to participate in Paramount Financial investments; that Ryan and Paramount Financial were not registered with the Commission as investment advisers; and that Paramount Financial did not invest the investors' funds as promised.

C. Grandy

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

1. Grandy was associated with Paramount Financial when he solicited and induced clients and other associates to invest. Grandy claimed to investors that Paramount Financial was a hedge fund that generated large returns for clients. Paramount Financial and Grandy were not registered with the Commission as investment advisers. Grandy, age 34, resides in Columbus, Ohio.

2. On September 27, 2004, a final judgment was entered by consent against Grandy, permanently enjoining him from future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled SEC v. Cummings, et al.

3. The Commission's complaint alleged that Grandy solicited and induced clients to participate in Paramount Financial investments. Grandy and Paramount Financial are not registered with the Commission as investment advisers.

D. Conley

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

1. Conley was a Paramount Financial employee from July 1999 through at least August 2001. Conley opened and conducted transactions in various bank accounts as part of the Paramount Financial scheme. Conley also falsely claimed to be president of a New York broker-dealer in connection with one of Paramount Financial's fraudulent schemes. Conley is a licensed broker with Series 7 and 24 securities licenses. Conley, age 33, resides in Columbus, Ohio.

2. On September 27, 2004, a final judgment was entered by consent against Conley, permanently enjoining him from future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled SEC v. Cummings, et al.

3. The Commission's complaint alleged that Conley opened and conducted transactions in various bank accounts used to deposit investor funds and wrote checks to investors which did not clear in furtherance of Paramount Financial's fraudulent schemes. Conley also falsely claimed to be president of a New York broker-dealer in connection with one of Paramount Financial's fraudulent schemes. Conley had Series 7 and 24 licenses.

E. Vogt

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

1. Vogt is a licensed broker and registered representative who solicited and induced clients and other associates to invest in Paramount Financial, a purported hedge fund that was falsely represented to investors as generating large returns for clients. In fact, Paramount Financial was not a hedge fund and did not buy or sell securities for clients' accounts but used investor funds to repay prior investors and for personal and business expenses. Vogt, age 31, is a resident of Clearwater, Florida.

2. On September 27, 2004, a final judgment was entered by consent against Vogt, permanently enjoining him from future violations of Section 15(a) of the Exchange Act in the civil action entitled SEC v. Cummings, et al.

3. The Commission's complaint alleged that Vogt solicited and referred clients to participate in Paramount Financial investments. Vogt did not disclose to his registered broker-dealer employer that he had solicited investors for Paramount Financial in exchange for fees and commissions from Paramount Financial in the approximate amount of $104,000. Vogt agreed to use nominee accounts to disguise the use of investor funds to pay his commissions.

F. Hawley

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

1. Hawley is a licensed broker and registered representative who solicited and induced clients to invest in Paramount Financial, a purported hedge fund that was falsely represented to investors as generating large returns for clients. In fact, Paramount Financial was not a hedge fund and did not buy and sell securities for clients' accounts, but used investor funds to repay prior investors and for personal and business expenses. Hawley, age 33, is a resident of Mount Vernon, New York.

2. On September 27, 2004, a final judgment was entered by consent against Hawley, permanently enjoining him from future violations of Section 15(a) of the Exchange Act, in the civil action entitled SEC v. Cummings, et al.

3. The Commission's complaint alleged that Hawley solicited and referred clients to participate in Paramount Financial investments. Hawley did not disclose to his registered broker-dealer employer that he had solicited investors for Paramount Financial in exchange for fees and commissions from Paramount Financial in the approximate amount of $80,000. Hawley agreed to use nominee accounts to disguise the use of investor funds to pay his commissions.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions agreed to in Respondents' Offers.

Accordingly, it is hereby ORDERED:

A. Pursuant to Section 203(f) of the Advisers Act, that Respondents Cummings, Ryan, Grandy and Conley be, and hereby are barred from association with any investment adviser;

B. Pursuant to Section 15(b)(6) of the Exchange Act, that Respondent Conley be, and hereby is barred from association with any broker or dealer;

C. Pursuant to Section 15(b)(6) of the Exchange Act, that Respondents Vogt and Hawley be, and hereby are barred from association with any broker or dealer, with the right to reapply for association after one year to the appropriate self-regulatory organization, or if there is none, to the Commission.

Any reapplication for association by the Respondents will be subject to the applicable laws and regulations governing the reentry process, and reentry may be conditioned upon a number of factors, including, but not limited to, the satisfaction of any or all of the following: (a) any disgorgement ordered against the Respondent, whether or not the Commission has fully or partially waived payment of such disgorgement; (b) any arbitration award related to the conduct that served as the basis for the Commission order; (c) any self-regulatory organization arbitration award to a customer, whether or not related to the conduct that served as the basis for the Commission order; and (d) any restitution order by a self-regulatory organization, whether or not related to the conduct that served as the basis for the Commission order.

By the Commission.