Investment Advisers Act of 1940
             Release No.    1758 / September 25, 1998

             Administrative Proceeding
             File No.  3-9727


             ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS INSTITUTED
             AGAINST PANKOWSKI ASSOCIATES, INC. AND JOSEPH R. PANKOWSKI

             The Securities and Exchange Commission ("Commission")
             announced that it has instituted public administrative and
             cease-and-desist proceedings against Pankowski Associates,
             Inc. ("PAI"), a registered investment adviser, and Joseph R.
             Pankowski ("Pankowski"), PAI's CEO and majority owner,
             pursuant to Sections 203(e), (f), and (k) of the Investment
             Advisers Act of 1940 ("Advisers Act").

             The Commission's Order Instituting Public Proceedings
             ("Order") alleges that PAI, which provides a market timing
             service, misrepresented its performance results in
             advertisements sent to broker-dealers in order to attract
             clients; and failed to maintain records necessary to
             substantiate its advertised performance claims.  Pankowski
             aided and abetted PAI's violations.  Specifically, the Order
             alleges that PAI willfully violated, and Pankowski caused
             and willfully aided and abetted PAI's violations of,
             Sections 206(1), 206(2) and 206(4) of the Advisers Act and
             Rule 206(4)-1(a)(5) thereunder, by misrepresenting that
             PAI's date of inception was 1968, when it did not exist
             prior to 1978;  by failing to disclose that a 27% average
             annual rate of return claimed for the period 1970 through
             1980 was generated by applying a timing model retroactively
             to a hypothetical investment in several mutual funds, and
             that PAI did not exist during most of this period; by
             claiming performance results that no PAI client achieved or
             could have achieved; and by failing to disclose that the
             market timing model used by PAI after 1991 differed
             materially from the model used before 1991 and that the
             earlier model was no longer available to PAI clients.

             The Order also alleges that PAI willfully violated, and
             Pankowski caused and willfully aided and abetted PAI's
             violations of, Section 204 of the Advisers Act and Rule 204-
             2(a)(16) thereunder by failing to retain documents necessary
             to demonstrate the calculation of the rates of return
             claimed in the advertisements.

             A  hearing will be scheduled to determine whether the
             allegations contained in the Order are true, and if so, to
             determine what remedial sanctions, if any, are appropriate
             and in the public interest.