Order Instituting Proceedings, Release No. 33-9481

Order Instituting Administrative and Cease-and-Desist Proceedings Pursuant to Section 8a of the Securities Act of 1933, Sections 15(b) 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