Michael B. Rawdin, Hard Asset Management, Inc. and David Cohen

SECURITIES ACT OF 1933
Release No. 8270 / August 20, 2003

SECURITIES EXCHANGE ACT OF 1934
Release No. 48380 / August 20, 2003

ADMINISTRATIVE PROCEEDING
File No. 3-11234

In the Matter of Michael B. Rawdin, Hard Asset Management, Inc.
and David Cohen

The United States Securities and Exchange Commission ("Commission") has instituted public administrative and cease-and-desist proceedings against Michael B. Rawdin ("Rawdin"), Hard Asset Management, Inc. ("Hard Asset") and David Cohen ("Cohen") of Dix Hills, New York and Coconut Creek, Florida, respectively, pursuant to Section 8A of the Securities Act of 1933 ("Securities Act") and Sections 15(b) and 21C of the Securities Exchange Act of 1934 ("Exchange Act"). The proceedings have been instituted to determine whether remedial sanctions and a cease-and-desist order should be imposed against them. The Order Instituting Public Administrative and Cease-and-Desist Proceedings pursuant to Section 8A of the Securities Act of 1933 and Sections 15(b) and 21C of the Securities Exchange Act of 1934 ("Order") alleges that Hard Asset and its president and sole principal, Rawdin, were unregistered broker-dealers. The Order also alleges that Cohen was an unregistered broker-dealer. The Order further alleges that from October 2001 through May 2002, Rawdin, Hard Asset, and Cohen willfully violated, and committed or caused violations of, Sections 5(a), 5(c), 17(a)(1), 17(a)(2) and 17(a)(3) of the Securities Act and Sections 10(b) and 15(a)(1) of the Exchange Act and Rule 10b-5 thereunder in connection with their participation in the unregistered offer and sale to the public of securities in the form of agreements issued by Starcash, Inc. A hearing will be scheduled to determine whether the allegations are true, to afford Respondents an opportunity to establish any defenses thereto, and to determine whether remedial sanctions and a cease-and-desist order should be imposed against them.

Jonathan G. Katz
Secretary