UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION SECURITIES EXCHANGE ACT OF 1934 Release No. 39039 / September 10, 1997 ACCOUNTING AND AUDITING ENFORCEMENT Release No. 952 / September 10, 1997 ADMINISTRATIVE PROCEEDING File No. 3-9396 ___________________________________ : ORDER INSTITUTING PUBLIC In the Matter of : PROCEEDINGS PURSUANT TO : SECTION 15(b)(6) OF THE MICKIE E. HIGGINS-HALLKE, CPA : SECURITIES EXCHANGE ACT OF : 1934 AND RULE 102(e) OF Respondent. : THE COMMISSION'S RULES OF : PRACTICE, 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 pursuant to Section 15(b)(6) of the Securities Exchange Act of 1934 ("Exchange Act") and Rule 102(e) the Commission's Rules of Practice be, and they hereby are, instituted against Mickie E. Higgins-Hallke ("Higgins-Hallke"). II. In anticipation of the institution of these administrative proceedings, Higgins-Hallke 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 to which the Commission is a party, Higgins-Hallke, without admitting or denying the findings set forth herein, except as to the entry of the injunction set forth in paragraph III.F. and the Commission's jurisdiction over her, both of which are admitted, consents to the entry of this Order Instituting Public Proceedings Pursuant to Section 15(b)(6) of the Exchange Act and Rule 102(e) of the Commission's Rules of Practice, Making Findings and Imposing Remedial Sanctions. III. Based on this Order and Higgins-Hallke's Offer, the Commission finds<(1)> the following: A. Higgins-Hallke is a certified public accountant licensed by the State of Georgia. Higgins-Hallke was the chief financial officer of Paragon Mortgage Corporation ("Paragon") from November 1, 1991 through March 15, 1994. Higgins-Hallke practiced before the Commission within the meaning of Rule 102(f) of the Commission's Rules of Practice in connection with the preparation of Paragon's financial statements and other documents. B. Paragon was a mortgage banking firm headquartered in Smyrna, Georgia. It was incorporated in Illinois on May 27, 1988, commenced operations in September 1988, conducted its initial public offering on August 8, 1989, and was dissolved on October 1, 1994. Paragon's operations included originating residential real estate loans and selling the resulting mortgage secured notes in the secondary mortgage market, brokering mortgage loans and servicing mortgage loans. Paragon's common stock was registered pursuant to Section 12(g) of the Exchange Act. C. During 1992, 1993 and 1994, Higgins-Hallke participated in the offering of Paragon's common stock, which was a penny stock. D. On August 22, 1997, the Commission filed a civil injunctive action against Higgins-Hallke and others [Securities and Exchange Commission v. Wyatt Gene Ross, Lynn K. Ross, and Mickie E. Higgins-Hallke, Civil Action No. 97-CV-2431-JEC, (N.D. Ga.)], alleging that Higgins-Hallke violated Section 17(a) of the Securities Act of 1933 ("Securities Act"), and Sections 10(b) and 13(b)(5) of the Exchange Act and Rules 10b-5 and 13b2-1 thereunder, and charging her with liability, as a control person, for violations of Sections 13(a), 13(b)(2)(A) and 13(b)(2)(B) of the Exchange Act and Rules 12b-20, 13a-1, 13a-11 and 13a-13 thereunder. E. The Commission's complaint alleged that between 1992 and 1994 Higgins-Hallke prepared or assisted in the preparation of financial statements contained in certain periodic reports and in a registration statement filed on behalf of Paragon with the Commission. The reports and registration statement materially misrepresented the operations and financial condition of Paragon in violation of generally accepted accounting principles. Also, one of these reports failed to disclose a disagreement between <(1)> The findings herein are made pursuant to Higgins- Hallke's Offer and are not binding on any other person or entity named as a respondent in this or any other proceeding. ======END OF PAGE 2====== Paragon and its then outside auditors. The complaint further alleged that Higgins-Hallke failed to make and keep accurate books and records and failed to establish and maintain adequate internal accounting controls. F. On August 26, 1997, without admitting or denying any of the allegations contained in the Commission's complaint, Higgins- Hallke consented to the entry of an order of permanent injunction permanently enjoining her from violations of Section 17(a) of the Securities Act, and Sections 10(b), 13(a), 13(b)(2)(A), 13(b)(2)(B) and 13(b)(5) of the Exchange Act and Rules 10b-5, 12b-20, 13a-1, 13a-11, 13a-13 and 13b2-1 thereunder. IV. Based on the foregoing, the Commission deems it appropriate and in the public interest to accept the Offer submitted by Higgins-Hallke and accordingly, IT IS HEREBY ORDERED, effective immediately, that: 1. Mickie E. Higgins-Hallke is permanently denied the privilege of appearing or practicing before the Commission as an accountant. 2. Mickie E. Higgins-Hallke be, and hereby is, barred from participating in any offering of penny stock. By the Commission Jonathan G. Katz Secretary ======END OF PAGE 3======