UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
INVESTMENT ADVISERS ACT OF 1940
Release No. 2374 / April 6, 2005
ADMINISTRATIVE PROCEEDING
File No. 3-11882
In the Matter of
:
ORDER INSTITUTING
:
ADMINISTRATIVE AND CEASE-
Michael T. Jackson and
:
AND-DESIST PROCEEDINGS,
EGM Capital,
:
MAKING FINDINGS, AND
:
IMPOSING REMEDIAL SANCTIONS
Respondents.
:
AND A CEASE-AND-DESIST ORDER
_________________________:
PURSUANT TO SECTIONS 203(f) and
203(k) OF THE INVESTMENT
ADVISERS ACT OF 1940
I.
The Securities and Exchange Commission (“Commission”) deems it appropriate and in the
public interest that public administrative and cease-and-desist proceedings be, and hereby are,
instituted pursuant to Sections 203(f) and 203(k) of the Investment Advisers Act of 1940 (“Advisers
Act”) against Michael T. Jackson (“Jackson”) and EGM Capital, a California corporation (“EGM
Capital”) (collectively, “Respondents”).
II.
In anticipation of the institution of these proceedings, Respondents have submitted a joint
Offer of Settlement (“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 them and the subject matter of these
proceedings, Respondents consent to the entry of this Order Instituting Administrative and Cease-
and-Desist Proceedings, Making Findings, and Imposing Remedial Sanctions and a Cease-and-
Desist Order Pursuant to Sections 203(f) and 203(k) of the Investment Advisers Act of 1940
(“Order”), as set forth below.