UNITED STATES OF AMERICA
                            Before the
                SECURITIES AND EXCHANGE COMMISSION


INVESTMENT ADVISERS ACT OF 1940
Release No. 1615  /  February 18, 1997

ADMINISTRATIVE PROCEEDING
File No.  3-9249
______________________________
                              :
In The Matter of              :    ORDER INSTITUTING PROCEEDINGS
                              :    PURSUANT TO SECTION 203(f) OF
KENT A. AHRENS,               :    THE ADVISERS ACT, MAKING 
                              :    FINDINGS AND IMPOSING
                              :    REMEDIAL SANCTIONS
          Respondent.         : 
                              :
------------------------------

                                I.

     The Securities and Exchange Commission ("Commission") deems
it appropriate and in the public interest that public
administrative proceedings be, and they hereby are, instituted
pursuant to Section 203(f) of the Investment Advisers Act of 1940
("Advisers Act") to determine whether Kent Ahrens ("Respondent")
violated Section 10(b) of the Exchange Act, Rule 10b-5
thereunder, and Sections 206(1) and (2) of the Advisers Act.

     In anticipation of the institution of these administrative
proceedings, Respondent has submitted an Offer of Settlement
which the Commission has determined to accept.  Solely for the
purposes of this proceeding and any other proceeding brought by
or on behalf of the Commission or to which the Commission is a
party, and without admitting or denying the findings set forth
herein, with the exception of the entry of a permanent injunction
against him referred to in paragraph II.B. below and the
jurisdiction of the Commission over him in this matter, which are
admitted, Kent Ahrens consents to the institution of public
administrative proceedings, and the findings and remedial
sanctions set forth below.

     Accordingly, IT IS ORDERED that proceedings pursuant to
Section 203(f) of the Advisers Act be, and hereby are,
instituted.

                               II.

     On the basis of this Order Instituting Proceedings Pursuant
to Section 203(f) of the Advisers Act Making Findings and
Imposing Remedial Sanctions ("Order") and the Offer submitted by
==========================================START OF PAGE 2======

Kent Ahrens, the Commission finds that-[1]-:

     A.   Kent Ahrens, a resident of York, Pennsylvania, was the
senior trader in charge of the equity index arbitrage program at
First Capital Strategists, an investment adviser registered with
the Commission.

     B.   On October 22, 1996, Kent Ahrens was permanently
enjoined from violations of Section 10(b) of the Securities
Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections
206(1) and (2) of the Investment Advisers Act of 1940, by the
United States District Court for the Middle District of
Pennsylvania [SEC v. Kent A. Ahrens, 1 96 CV 1854 (J.Rambo)]. 
Ahrens consented to the entry of the permanent injunction without
admitting or denying any violation of the federal securities
laws.

     C.   The Commission's Complaint alleged that Ahrens
knowingly engaged in unauthorized trading, in violation of the
antifraud provisions of the federal securities laws.  The
Complaint alleged that from 1992 through June 1995, Ahrens, while
trading in the equity index arbitrage program for The Common
Fund, engaged in unauthorized trading that resulted in losses of
$137.6 million, and concealed those losses from First Capital and
The Common Fund.

                               III.

                       OFFER OF SETTLEMENT

     The Respondent has submitted an Offer of Settlement, in
which he, without admitting or denying the findings herein,
consents to the Commission's issuance of this Order which makes
findings, as set forth above, and orders that Ahrens be barred
from association with any broker, dealer, investment adviser or
municipal securities dealer.

                               IV.

                              ORDER

     Based on the foregoing, the Commission finds it appropriate
and in the public interest to accept the Offer submitted by the 


---------FOOTNOTES----------
     -[1]-     The findings  herein are made pursuant  to Kent A.
               Ahrens' Offer of Settlement and are not binding on
               any other  person or entity  in this or  any other
               proceeding.
==========================================START OF PAGE 3======

Respondent and to impose the relief consented to therein.

     Accordingly, IT IS HEREBY ORDERED that:

     Kent A. Ahrens be, and hereby is, barred from association
with any broker, dealer, investment company, investment adviser
or municipal securities dealer.

By the Commission.


                              Jonathan G. Katz
                              Secretary