NASD

NASD RULE 2110 AND SEC RULES 10B-9, 15C2-4 - RESPONDENT MEMBER ACTING THROUGH RESPONDENT MALONE, ACTED AS THE PLACEMENT AGENT FOR LIMITED PARTNERSHIP OFFERINGS AND WITHDREW FUNDS FROM THE ESCROW ACCOUNTS PRIOR TO THE REQUIRED AMOUNT OF UNITS BEING SOLD IN BONA FIDE TRANSACTIONS AND FAILED TO PROPERLY ESCROW FUNDS FROM SALES OF UNITS IN THE OFFERINGS; AND, RELEASED FUNDS FROM CONTINGENCY OFFERINGS PRIOR TO THE TERMS OF THE CONTINGENCY BEING MET WHEN THE PRIVATE PLACEMENT MEMORANDUM INDICATED THAT THE OFFERING WOULD BE ON AN "ALL-OR-NONE" BASIS.

Acceptance, Waiver & Consent(AWC)

Censure

Civil and Administrative Penalty(ies)/Fine(s)

CENSURED AND FINED $6,000 JOINTLY AND SEVERALLY ** FINES PAID 12/03/1999.

ON NOVEMBER 18, 1999 AWC WAS FINALIZED AND DJM FINANCIAL ADVISORY HAS PAID A $6,000 FINE, AND WAS CENSURED.