UNITED STATES OF AMERICA
                                     before the 
                          SECURITIES AND EXCHANGE COMMISSION



     SECURITIES EXCHANGE ACT OF 1934
     Rel. No. 40011 / May 20, 1998

     Admin. Proc. File No. 3-8206 
     _____________________________________________
                                                  :
                 In the Matter of                 :
                                                  :   ORDER
                 PAUL C. KETTLER                  :   DISMISSING              
                 7435 S. Yates Blvd.              :   PROCEEDINGS                 
                 Chicago, Illinois                :                                                       
                                                  :            
     _____________________________________________:


          On October 26, 1993, this Commission instituted proceedings against

     Paul C. Kettler, doing business as Kettler & Company, a registered broker-

     dealer, alleging that he had failed, during July 1988, reasonably to

     supervise one of his branch managers with a view to preventing that branch

     manager's violation of the federal securities laws.  On June 27, 1995, an

     initial decision was issued making findings consistent with those

     allegations.  On August 10, 1995, Kettler's petition for review of the

     initial decision was granted.

          On February 12, 1998, Kettler moved to dismiss these proceedings based

     upon the statute of limitations contained in 28 U.S.C. Section 2462, which

     requires an agency to commence "an action, suit, or proceeding for the

     enforcement of any civil fine, penalty, or forfeiture, pecuniary or

     otherwise," within five years. *<(1)>  Our Division of Enforcement
                              

          <(1)>/    See Johnson v. SEC, 87 F.3d 484 (D.C. Cir. 1996)
               (holding that Section 2462 prohibited the Commission from
               imposing a censure and a supervisory suspension in an
               administrative proceeding because the proceeding had been
               initiated more than five years after the conduct at issue).

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     does not oppose Kettler's motion to dismiss, although the Division's

     response expressly declines to address the merits of Kettler's motion. 

     Under the circumstances, and without reaching the question of the

     application of Section 2462 to the proceedings, in the exercise of our

     discretion, we have determined to dismiss the proceedings.  We intimate no

     view on the merits.

          Accordingly, IT IS ORDERED that these proceedings be, and they hereby

     are, dismissed.

          By the Commission.







                                        Jonathan G. Katz

                                           Secretary


























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