UNITED STATES SECURITIES AND EXCHANGE COMMISSION SECURITIES ACT OF 1933 Release No. 7617 / December 10, 1998 SECURITIES EXCHANGE ACT OF 1934 Release No. 40772 / December 10, 1998 INVESTMENT COMPANY ACT OF 1940 Release No. 23595 / December 10, 1998 ADMINISTRATIVE PROCEEDING File No. 3-9788 ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS INSTITUTED AGAINST MICHAEL P. TRABA The Securities and Exchange Commission ("Commission") announced that it issued an Order Instituting Public Administrative and Cease-And-Desist Proceedings Pursuant to Section 8A of the Securities Act of 1933, Sections 15(b) and 21C of the Securities Exchange Act of 1934, and Sections 9(b) and 9(f) of the Investment Company Act of 1940 ("Order") against Michael P. Traba, alleging fraud and other violations of the federal securities laws. In 1994, the time of the conduct, Traba was an employee of First National Bank of Chicago ("First Chicago") and senior portfolio manager of two money market mutual funds advised by First Chicago: the First Prairie Cash Management Fund and First Prairie Money Market Fund. The Order alleges that in 1994, Traba carried out a scheme to hide significant price declines in several derivative securities owned by the money market funds. For several months, Traba allegedly valued the derivatives at or near their original purchase prices, at a time when their market values had declined significantly. By valuing the derivatives at inflated prices, Traba disguised the fact that on several occasions, the true net asset value of the two money market funds fell below $1.00 per share. When instructed to sell the derivatives, Traba allegedly arranged a shell game by selling the derivatives and other securities at inflated prices to trust accounts under his control, thus transferring losses from the mutual funds to the trust accounts. Through this conduct, Traba allegedly violated 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 Section 34(b) of the Investment Company Act of 1940. Traba also allegedly caused and aided and abetted violations of Section 31(a) of the Investment Company Act of 1940 and Rules 22c-1 and 31a-1 thereunder. A hearing before an administrative law judge will be scheduled to determine whether the allegations in the Order are true and, if so, whether a cease-and-desist order should be entered and what, if any, other remedial sanctions are appropriate in the public interest.