==========================================START OF PAGE 1====== UNITED STATES SECURITIES AND EXCHANGE COMMISSION Securities Act of 1933 Release 7337 / September 26, 1996 Securities Exchange Act of 1934 Release 37729 / September 26, 1996 Investment Advisers Act of 1940 Release 1581 / September 26, 1996 Investment Company Act of 1940 Release 22250 / September 26, 1996 Administrative Proceedings File 3-9100 IN THE MATTER OF MICHAEL C. ROBERTSON AND M.C. ROBERTSON & ASSOCIATES, INC. The Commission announced on September 26, 1996, public administrative proceedings were instituted against Michael C. Robertson ("Robertson") and M.C. Robertson & Associates, Inc. ("MCR & Associates") alleging willful violations of Section 17(a) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1) and (2) of the Investment Advisers Act of 1940. Robertson was, through June 1994, the investment adviser to the Employees' Retirement Fund for the City of Fort Worth ("Fort Worth ERF"), a municipal retirement system providing disability and retirement benefits to Fort Worth city employees, and is the investment adviser to the Oklahoma Police Pension Retirement System ("Oklahoma Police PRS"), a pension system benefiting Oklahoma law enforcement personnel. The Order Instituting Proceedings alleges that from in or about July 1989 through June 1994, Robertson and MCR & Associates made materially false and misleading statements and omissions regarding his receipt of compensation from broker-dealers and mutual funds in connection with his activities as an investment adviser. The Order alleges that Robertson and MCR & Associates received approximately $721,460.93 in undisclosed service fees paid by three mutual funds in the Fort Worth ERF's portfolio. The Order further alleges that, from October 1991 through July 1994, Robertson and MCR & Associates received undisclosed commission payments totalling $13,863.72 in connection with the Fort Worth ERF commission recapture program. Finally, the Order alleges that, from December 1991 through July 1994, Robertson and MCR & Associates received undisclosed commission payments totalling $48,205.12 in connection the Oklahoma Police PRS commission recapture program. ==========================================START OF PAGE 2====== A hearing will be scheduled to determine whether the allegations are true, and if so, whether disgorgement, plus prejudgment interest, civil penalties, a cease-and-desist order, or other remedial sanctions are appropriate.