ia-4854.pdf

Order Modifying Order Instituting Administrative and Cease-And- Desist Proceedings, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order Pursuant to Sections 203(e), 203(f), and 203(k) of the Investment Advisers Act of 1940,\
and Sections 9(b) and 9(f) of the Investment Company Act of 1940