==========================================START OF PAGE 1====== UNITED STATES OF AMERICA Before the SECURITIES AND EXCHANGE COMMISSION INVESTMENT ADVISERS ACT OF 1940 Release No. 1611/ January 24, 1997 ADMINISTRATIVE PROCEEDING FILE NO. 3-9059 _________________________ In the Matter of : : ORDER MAKING FINDINGS RONALD M. ZOOK : AND IMPOSING REMEDIAL : SANCTIONS BY DEFAULT _________________________: Ronald M. Zook ( Mr. Zook ) is in default under the Securities and Exchange Commission s ( Commission ) Rules of Practice, Rules 155 and 220(f), 17 C.F.R.  201.155 and .220(f) (1996), because he failed to answer both the Order Instituting Public Proceedings which the Commission issued on August 8, 1996, and the Show Cause Order which I issued on January 2, 1997. Accordingly, I find that the allegations in the Order are true: A. Financial Concepts Group International, Inc. ( FCGI ) became registered with the Commission as an investment adviser on May 25, 1994.1 During relevant times herein, Mr. Zook was FCGI's president and sole shareholder. B. On February 7, 1995, the Commission filed a complaint against FCGI and Mr. Zook alleging, among other things, that from at least May 25, 1994 to February 7, 1995, FCGI and Mr. Zook failed to: (a) make and keep books and records and provide written disclosure statements to their clients, as prescribed under the Advisers Act; and (b) establish, maintain, and enforce written policies and procedures reasonably designed, taking into consideration the nature of FCGI's investment adviser business, to prevent the misuse of material, non-public information by FCGI and Mr. Zook or any person associated with FCGI and Mr. Zook. C. On March 20, 1995, a final judgment of permanent injunction was entered, by consent, against FCGI and Mr. Zook, permanently enjoining them from future violations, as aiders and 1 Pursuant to delegated authority, on May 9, 1996, FCGI's registration as an investment adviser was canceled, pursuant to Section 203(h) of the Investment Advisers Act of 1940 ("Advisers Act"). ==========================================START OF PAGE 2====== abettors or otherwise, of Sections 204 and 204A of the Advisers Act and Rules 204-2(a)(1), (3), (4), (5), (7), (10), (13), (14), and (15); 204-3(a), (b) and (c); 204-2(b)(1), (2), (3) and (4); 204-2(c)(1) and (2); and 204-2(e)(1) and (2), thereunder. SEC v. Financial Concepts Group International, Inc., et al., Case No. 95-117-CIV-ORL-19 (M.D.Fla.) D. On August 7, 1995, the Commission filed a complaint against FCGI and Mr. Zook alleging that from at least late 1992 through March 1995, FCGI and Mr. Zook defrauded at least 195 investors residing in at least 21 states of a total of approximately $6 million, by soliciting them to invest in investment contracts involving "prime bank" instruments. The complaint further alleged that instead of investing in "prime bank" instruments, FCGI and Mr. Zook used investor funds to, among other things: (a) pay Mr. Zook's personal expenses; (b) make "interest" payments to other investors; and (c) provide interest-free loans to various private corporations of which Mr. Zook is an officer and/or shareholder. E. On January 24, 1996, a final judgment of permanent injunction was entered, upon default, against FCGI and Mr. Zook enjoining them from future violations of Sections 5(a), 5(c) and 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934, and Rule 10b-5, thereunder. SEC v. Ronald M. Zook, et al., Case No. 95-798-CIV-ORL-22 (M.D. Fla.). I find further that it is in the public interest to bar Mr. Zook from association with any investment adviser. Accordingly, I ORDER that Ronald M. Zook is barred from being associated with an investment adviser pursuant to Section 203(f) of the Investment Advisers Act of 1940. I FURTHER ORDER that the hearing scheduled to begin on January 27, 1997, be, and hereby is, canceled. __________________________________ Brenda P. Murray Chief Administrative Law Judge