The Securities and Exchange Commission

[Stock]

IA-2606 May 23, 2007 Allocation Plus Asset Management Company, Inc.
http://www.sec.gov/litigation/admin/2007/ia-2606.pdf

UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
INVESTMENT ADVISERS ACT OF 1940
Release No. 2606 / May 23, 2007
ADMINISTRATIVE PROCEEDING
File No. 3-12641
In the Matter of
ALLOCATION PLUS ASSET MANAGEMENT COMPANY, INC.,
Respondent.
ORDER INSTITUTING
ADMINISTRATIVE PROCEEDINGS PURSUANT TO SECTION 203(e) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS
I.
The Securities and Exchange Commission (“Commission”) deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted pursuant to Section 203(e) of the Investment Advisers Act of 1940 (“Advisers Act”) against Allocation Plus Asset Management Company, Inc. (“APAM” or “Respondent”).
II.
In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the “Offer”) 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 the findings herein, except as to the Commission’s jurisdiction over it and the subject matter of these proceedings, and the findings contained in Section III.2 below, which are admitted, Respondent consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Section 203(e) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions (“Order”), as set forth below.
2
III.
On the basis of this Order and Respondent’s Offer, the Commission finds that:
1. APAM is an investment adviser registered with the Commission from March 1994 to the present. Bradford C. Bleidt (“Bleidt”) was the sole shareholder, officer and director of APAM.
2. On May 8, 2007, a final judgment was entered by consent against APAM and Bleidt, permanently enjoining both from future violations of Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act, in the civil action entitled Securities and Exchange Commission v. Bradford C. Bleidt, et al., Civil Action Number 104-12415-NG, in the District of Massachusetts.
3. The Commission’s complaint alleged that Bleidt, through APAM, diverted investor funds into his personal bank account, falsely stated to investors that their funds were invested, and otherwise engaged in a variety of conduct which operated as a fraud and deceit on investors.
IV.
In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions agreed to in Respondent APAM’s Offer.
Accordingly, it is hereby ORDERED:
Pursuant to Section 203(e) of the Advisers Act, that the registration of Respondent APAM be, and hereby is revoked.
By the Commission.
Nancy M. Morris
Secretary