James Oh

INVESTMENT ADVISERS ACT OF 1940
Release No. 2029 / April 18, 2002

ADMINISTRATIVE PROCEEDING
File No. 3-10759

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest to institute a public administrative proceeding pursuant to Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act") against James Oh ("Oh").

Accordingly, IT IS HEREBY ORDERED that said proceeding be, and hereby is, instituted.

II.

In anticipation of the institution of this proceeding, Respondent has submitted an Offer of Settlement ("Offer"), which the Commission has determined to accept. Solely for the purpose of this proceeding and any other proceeding brought by or on behalf of the Commission or in which the Commission is a party, and without admitting or denying the findings contained herein, except that Respondent admits the jurisdiction of the Commission over him and over the subject matter of this proceeding and admits the entry of the Judgment of Permanent Injunction set forth in paragraph III.C., Respondent consents to the entry of this Order Instituting Public Administrative Proceeding, Making Findings, And Imposing Remedial Sanction ("Order").

III.

On the basis of this Order and Respondent's Offer, the Commission finds that:

1. James Oh, age 35, during the relevant period, resided in Portland, Oregon. From May 1996 to June 1999, he was a principal of Cascade Asset Management Co., LLC, a registered investment adviser. From June 1999 until November 1, 1999, he was associated with IMS Capital Management, Inc., another registered investment adviser.

2. On March 21, 2002, the Commission filed an action against Oh in the United States District Court for the District of Oregon. The Complaint filed in that action alleges, among other things, that Oh, a portfolio manager formerly associated with two registered investment advisers, misappropriated over $500,000 from clients. The Complaint further alleges that from April 1999 through January 2000, Oh misappropriated client funds by telling clients about purported investment opportunities and then directing the clients to forward funds to him by check or wire for the investment. The Complaint also alleges that Oh did not invest the funds on his clients' behalf; rather, he deposited the client funds into his personal bank accounts, commingled the client funds with his and used the misappropriated funds for personal expenses, such as credit card and car payments.

3. On April 9, 2002, the United States District Court for the District of Oregon entered a Judgment of Permanent Injunction And Other Relief Against Oh ("Judgment"). The Judgment permanently enjoins Oh from violating Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act. SEC v. James Oh, Civil Action No. 02 361 HU.

IV.

Based on the foregoing, the Commission deems it appropriate and in the public interest to accept the Offer submitted by Respondent and to impose the remedial sanction specified in Respondent's Offer.

Accordingly, IT IS HEREBY ORDERED, effective immediately, that Respondent is barred from association with any investment adviser.

By the Commission.

Jonathan G. Katz
Secretary