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Order Instituting Proceedings, Release No. IA-3574

Order Instituting Proceedings, Release No. IA-3574
Order Instituting Administrative and Cease-And-Desist Proceedings, Pursuant to Sections 203(e), 203 (f), and 203(K) of the Investment Advisers Act of 1940 and Section 9(b) of the Investment Company Act of 1940