UNITED STATES OF AMERICA
                           Before the 
                SECURITIES AND EXCHANGE COMMISSION

INVESTMENT ADVISERS ACT OF 1940
Release No. 1544 / December 28, 1995

ADMINISTRATIVE PROCEEDING
File No. 3-8904

---------------------------
                           : 
                           :       ORDER INSTITUTING PUBLIC 
In the Matter of           :       ADMINISTRATIVE PROCEEDING
                           :       PURSUANT TO SECTION 203(f) OF
STEEN RONLOV               :       THE ADVISERS ACT OF 1940,
                           :       MAKING FINDINGS AND IMPOSING
                           :       SANCTIONS
---------------------------

                                I.

     The Securities and Exchange Commission ("Commission") deems
it appropriate and in the public interest to institute
proceedings against Steen Ronlov ("Ronlov" or "Respondent")
pursuant to Section 203(f) of the Investment Advisers Act of 1940
("Advisers Act").  Accordingly, IT IS HEREBY ORDERED that said
proceedings be, and hereby are, instituted.

                               II.

     Simultaneously with the institution of this proceeding,
Respondent has submitted an Offer of Settlement ("Offer") solely
for the purposes of these proceedings and any other proceedings
brought by or on behalf of the Commission, or in which the
Commission is a party.  Under the terms of the Offer, which the
Commission has determined to accept, Respondent, without
admitting or denying the matters set forth herein (except that
Respondent admits the jurisdiction of the Commission over him and

over the subject matter of this proceeding and the entry of the
order of permanent injunction) consents to the entry of this
Order Instituting Public Administrative Proceedings Pursuant to
Section 203(f) of the Investment Advisers Act of 1940, Making
Findings and Imposing Sanctions ("Order").

-------------------- BEGINNING OF PAGE #2 -------------------

                               III.

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

     A.   From 1987 through 1991, Ronlov was a salesman for
Steven D. Wymer ("Wymer"), the owner of two former California-
based registered investment advisory firms, Denman & Company
("Denman") (File No. 801-27314) and its successor, Institutional
Treasury Management ("ITM") (File No. 801-38214).  While in
control of Denman and ITM, Wymer defrauded his advisory clients
out of approximately $209 million, including prejudgment
interest.  Ronlov managed Wymer's Colorado operations through a
former registered investment adviser, Denman & Company of
Colorado (File No. 801-34295), which he co-owned with Wymer.

     B.   On  November 3, 1995, the Respondent was permanently
enjoined in the United States District Court for the Central
District of California from future violations of Section 17(a) of
the Securities Act of 1933 ("Securities Act") and Section 10(b)
of the Securities Exchange Act of 1934 ("Exchange Act") and Rule
10b-5 thereunder and aiding and abetting violations of Sections
206(1) and 206(2) of the Advisers Act.  SEC v. James A. Pearce
and Steen Ronlov, Civil Action No. CV 95-6533 (RJR) (C.D. Cal.).

     C.   The Commission's Complaint filed in the above action
alleged, among other things, that between 1987 and 1991, the
Respondent:  (1) solicited potential investment advisory clients
for Wymer knowing that Wymer would immediately misappropriate
their investments; (2) directly misappropriated an advisory
client's investment; (3) participated in fabricating and
reporting fictitious trades to Wymer's clients to cover up the
misappropriation; and (4) participated in Wymer's fraudulent
scheme of trading options in the name of ITM clients without the
knowledge or consent of the clients.

                               IV.

     Based upon the foregoing, the Commission deems it
appropriate and in the public interest to impose the sanctions
specified by Respondent in his Offer of Settlement.






















                                        - 2 -

-------------------- BEGINNING OF PAGE #3 -------------------

     Accordingly, IT IS HEREBY ORDERED, effective immediately,
that Respondent be, and hereby is barred from association with
any broker, dealer, investment company, investment adviser or
municipal securities dealer.

     By the Commission.





                                   Jonathan G. Katz
                                   Secretary


















































                                        - 3 -