THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION

08/22/01GS: SEC ADMINISTRATIVE PROCEEDING, RELEASE NO. 44679, RELEASE NO. 1967, FILE NO. 3-10555, DATED AUGUST 10, 2001 DISCLOSES: DURING 1998, ANDREW PARLIN, THEN A PRINCIPAL AND PORTFOLIO MANAGER AT A REGISTERED INVESTMENT ADVISOR FIRM ENGAGED IN A TRADING STRATEGY IN WHICH, AMONG OTHER THINGS, HE PLACED MARKET ORDERS TO PURCHASE SHARES IN FIVE SECURITIES HEAVILY OWNED BY PARLIN'S ADVISORY CLIENTS SHORTLY BEFORE THE CLOSE OF THE MARKET WITH THE PURPOSE OF INCREASING THE CLOSING PRICE OF THOSE SECURITIES, A PRACTICE KNOWN AS "MARKING THE CLOSE." AT THE TIME OF THE TRADING, THE CLIENT ACCOUNTS UNDER PARLIN'S MANAGEMENT MAINTAINED SUBSTANTIAL PORTFOLIO POSITIONS IN THE INVOLVED SECURITIES. BY INTENTIONALLY PAYING A HIGHER PRICE TO BUY SECURITIES AT THE END OF THE DAY AND THE END OF THE REPORTING PERIOD, PARLIN SOUGHT TO CAUSE, AND, IN SOME CASES CAUSED A SHORT-TERM INCREASE IN THE OVERALL VALUE OF CERTAIN SECURITIES HELD IN THE ACCOUNTS UNDER HIS MANAGEMENT. IN CERTAIN INSTANCES THE INCREASES IN CLOSING PRICE COINCIDED WITH FISCAL PERIOD ENDS. HOWEVER, PARLIN DID NOT SELL THESE SECURITIES BASED ON THE SHORT-TERM PRICE INCREASES. THE EVIDENCE, INCLUDING THE TRADING RECORDS AND TAPES OF CONTEMPORANEOUS CONVERSATIONS, REFLECTS THAT PARLIN ATTEMPTED TO MARK OR MARKED THE CLOSE IN THE SECURITIES. BY REASON OF THE FOREGOING, THE COMMISSION FINDS THAT ANDREW PARLIN WILLFULLY VIOLATED SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER,AND WILLFULLY AIDED AND ABETTED VIOLATIONS OF SECTIONS 206(1) AND (2) OF THE ADVISERS ACT.

Decision & Order of Offer of Settlement

Monetary/Fine

$75,000.00

Cease and Desist/Injunction

Suspension

CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, AND SECTIONS 206(1) AND (2) OF THE ADVISERS ACT; SUSPENDED FROM ASSOCIATION WITH ANY INVESTMENT ADVISER FOR A PERIOD OF 12 MONTHS, EFFECTIVE THE SECOND MONDAY FOLLOWING THE ENTRY OF THE ORDER; AND PAY A CIVIL MONEY PENALTY OF $75,000, WITHIN TEN DAYS OF THE ENTRY OF THE ORDER

OECHSLE INTERNATIONAL ADVISORS

Voluntary Resignation

ALLEGATION THAT DURING 1998, ANDREW PARLIN, THEN A PRINCIPAL AND PORTFOLIO MANAGER AT OECHSLE, ENGAGED IN A TRADING STRATEGY IN WHICH HE PLACED MARKET ORDERS TO PURCHASE SHARES IN FIVE SECURITIES SHORTLY BEFORE THE CLOSE OF THE MARKET WITH THE PURPOSE OF INCREASING THE CLOSING PRICE OF THOSE SECURITIES.