UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

INVESTMENT ADVISERS ACT OF 1940
RELEASE NO. 2108 / February 6, 2003

ADMINISTRATIVE PROCEEDING
FILE NO. 3-10921

In the Matter of Paul J. House and Brandon R. Moore, Respondents.

: : : : : :

ORDER MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AGAINST PAUL J. HOUSE AND BRANDON R. MOORE PURSUANT TO SECTION 203(f) OF THE INVESTMENT ADVISERS ACT OF 1940

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest to accept the Offers of Settlement ("Offers") submitted by Paul J. House ("House") and Brandon R. Moore ("Moore") pursuant to Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act").

II.

In response to the entry of an Order Instituting Proceedings¹ pursuant to Section 203(f) of the Advisers Act, Respondents have submitted Offers which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission, or to which the Commission is a party, and without admitting or denying any findings contained herein, except as to the jurisdiction of the Commission over them and the subject matter of these proceedings and except for the findings contained in paragraph III. C. below, which are admitted, Respondents consent to the entry of this Order Making Findings and Imposing Remedial Sanctions against Paul J. House and Brandon R. Moore pursuant to Section 203(f) of the Investment Advisers Act of 1940 ("Order") as set forth below.

III.

On the basis of this Order and Respondents' Offers, the Commission finds that:

A. Respondent House from at least March 2000 until June 2002, was a managing member of House Asset Management, L.L.C. ("Adviser"). Respondent Moore, from at least December 2000 until June 2002, was an officer of the Adviser. From at least March 2002 until June 2002, Moore was the chief financial officer of the Adviser. The Adviser acted as the advisory entity to a hedge fund named House Edge, L.P. ("Hedge Fund"). The Hedge Fund had a stated strategy of investing primarily in stocks and options. As such, during the time periods stated above, Respondent House, Respondent Moore, and the Adviser were engaged in the investment advisory business and made use of the mails and other means and instrumentalities of interstate commerce in connection with their investment advisory business.

B. On June 20, 2002, the Commission filed a Complaint in the United States District Court for the Central District of Illinois against Respondents House and Brandon R. Moore captioned, SEC v. House Asset Management, L.L.C., et al., Case No. 02-2147. The Commission's Complaint alleged that the Respondents, from March 2000 until June 2002, raised approximately $2.9 million from at least 60 investors by selling the investors units in the Hedge Fund. The Complaint alleged that the Respondents, in the course of offering units to Hedge Fund investors, made materially false and misleading statements. According to the Complaint, the Respondents falsely told investors that the Hedge Fund had generated cumulative returns of up to 148% when the Hedge Fund had lost at least $850,000 during its operation. The Complaint alleged also that the Respondents misrepresented the use of proceeds to investors by claiming that the proceeds would be used to engage in a profitable securities trading program when Respondents borrowed at least $400,000 from the Hedge Fund to purchase real estate for themselves. Further, the Complaint alleged that the Respondents made false and misleading statements in offering materials about House's background as a broker and omitted to disclose the Respondents' prior personal bankruptcies.

C. On June 20, 2002, in SEC v. House Asset Management, L.L.C, et al., the Court entered an order permanently enjoining the Respondents from violating Sections 5(a), 5(c), 17(a)(1), 17(a)(2), and 17(a)(3) of the Securities Act of 1933, Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, Sections 206(1) and 206(2) of the Advisers Act, and Section 7(a) of the Investment Company Act of 1940 based on the conduct described above. The Respondents, without admitting or denying the allegations made in the Commission's Complaint, consented to the entry of the order of permanent injunction.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in Respondents' Offers.

Accordingly, it is ORDERED:

Pursuant to Section 203(f) of the Advisers Act, Respondents Paul J. House and Brandon R. Moore be, and hereby are, barred from association with any investment adviser.

For the Commission, by its Secretary, pursuant to delegated authority.

Jonathan G. Katz
Secretary

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1	Instituted October 25, 2002.

http://www.sec.gov/litigation/admin/ia-2108.htm