U.S. SECURITIES AND EXCHANGE COMMISSION


          Litigation Release No. 15918 / September 30, 1998

          UNITED STATES OF AMERICA V. BENJAMIN BUSH, Criminal Action No. 98
          CR 35 (C.D. Cal.)

               On September 28, 1998, Benjamin Bush ("Bush"), a formerly
          registered investment adviser and former president of the defunct
          investment advisory firm, Ben Bush Investment Management, Inc.
          ("BBIM"), was sentenced to 51 months in federal prison for
          stealing $1.3 million from his clients and ordered to pay
          restitution upon his release from prison.  The criminal action,
          by the U.S. Attorney's Office for the Central District of
          California, followed an enforcement action by the Securities and
          Exchange Commission which, on January 24, 1997, obtained consent
          judgments against Bush and BBIM based on the same conduct
          underlying the criminal action.  The consent judgments
          permanently enjoined Bush and BBIM from future violations of the
          antifraud provisions of the Securities Act of 1933, the
          Securities Exchange Act of 1934 and the Investment Advisers Act
          of 1940 ("Advisers Act"), as well as the custody and possession,
          books and records and filing requirements of the Advisers Act.
          The judgments further required Bush and BBIM to pay disgorgement,
          prejudgment interest and civil penalties.  The Commission also
          barred Bush from the securities industry and revoked BBIM's
          investment adviser registration.

               The Commission's complaint alleged that from January 1995
          through September 1996, Bush, through BBIM: misappropriated at
          least $450,000 from clients; sent clients account statements
          falsely showing that he had purchased investments on their behalf
          when he had not; commingled client and personal funds in a single
          bank account which he used to pay personal expenses such as rent
          and alimony, and to purchase personal items such as hockey
          tickets and jewelry; used forged brokerage statements to solicit
          business; and induced several clients to purchase 94 year old
          Brazilian bonds of uncertain value, which Bush kept in a personal
          safety deposit box at a local bank.

               On September 26, 1996, the Commission obtained a temporary
          restraining order which ordered Bush and BBIM to cease their
          fraudulent activities and froze Bush's assets.  This relief was
          continued by a preliminary injunction entered on October 4, 1996.
          On April 7, 1998, Bush plead guilty to one count of money
          laundering.  For further information, see Litigation Release Nos.
          15101, 15132, 15241 and 15710.