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U.S. Securities and Exchange Commission


Investment Advisers Act of 1940
Release No. 1800 \ May 4, 1999

Administrative Proceeding
File No. 3-9888

In the Matter of Apodaca Investment Group, Inc., Brower Financial Services, Inc., Ethical Investments, Inc., Ronald Allan McDow, Van Cleef Asset Management, Inc., and WWW Advisors, Inc.

The Securities and Exchange Commission ("Commission") instituted a cease-and-desist and administrative proceeding against six investment advisers for failing to timely file Form ADV-Y2K. The advisers are: Apodaca Investment Group, Inc. ("Apodaca") of San Francisco, California; Brower Financial Services, Inc. ("Brower") of Salt Lake City, Utah; Ethical Investments, Inc. ("Ethical") of Minneapolis, Minnesota; Ronald Allan McDow ("McDow") of Nashville, Tennessee; Van Cleef Asset Management, Inc. ("Van Cleef") of Beachwood, Ohio; and WWW Advisors, Inc. ("WWW") of Lexington, Kentucky. Form ADV-Y2K was designed to enable the Commission to evaluate the preparedness of investment advisers for the Year 2000. In the Order, the Division of Enforcement ("Division") alleges that Apodaca, Brower, McDow and Van Cleef, each of which reported assets under management of not less than $25 million, were required to and failed to file Part I of Form ADV-Y2K by December 7, 1998. The Division further alleges that Ethical and WWW failed to file Parts I and II of Form ADV-Y2K by December 7, 1998. Ethical and WWW were required to file both Parts I and II of Form ADV-Y2K because each reported that it advised an investment company registered under the Investment Company Act of 1940. Ethical also reported assets under management of not less than $25 million. The Order alleges that the respondents willfully violated Section 204 of the Investment Advisers Act of 1940 and Rule 204-5.

A hearing will be scheduled to determine whether the allegations are true and whether cease-and-desist orders, civil penalties and other sanctions are appropriate against these respondents.