2021-03896. Notice of Intention To Cancel Registrations of Certain Investment Advisers Pursuant to Section 203(H) of the Investment Advisers Act of 1940

February 22, 2021.

Notice is given that the Securities and Exchange Commission (the “Commission”) intends to issue an order or orders, pursuant to section 203(h) of the Investment Advisers Act of 1940 (the “Act”), cancelling the registrations of the investment advisers whose names appear in the attached Appendix, hereinafter referred to as the “registrants.”

Section 203(h) of the Act provides, in pertinent part, that if the Commission finds that any person registered under section 203, or who has pending an application for registration filed under that section, is no longer in existence, is not engaged in business as an investment adviser, or is prohibited from registering as an investment adviser under section 203A, the Commission shall by order cancel the registration of such person.

Each registrant listed in the attached Appendix either (a) has not filed a Form ADV amendment with the Commission as required by rule 204-1 under the Act ^[1] and appears to be no longer engaged in business as an investment adviser or (b) has indicated on Form ADV that it is no longer eligible to remain registered with the Commission as an investment adviser but has not filed Form ADV-W to withdraw its registration. Accordingly, the Commission believes that reasonable grounds exist for a finding that these registrants are no longer in existence, are not engaged in business as investment advisers, or are prohibited from registering as investment advisers under section 203A, and that their registrations should be cancelled pursuant to section 203(h) of the Act.

Notice is also given that any interested person may, by March 19, 2021, at 5:30 p.m., submit to the Commission in writing a request for a hearing on the cancellation of the registration of any registrant listed in the attached Appendix, accompanied by a statement as to the nature of such person's interest, the reason for such person's request, and the issues, if any, of fact or law proposed to be controverted, and the writer may request to be notified if the Commission should order a hearing thereon. Any such communication should be emailed to the Commission's Secretary at [e-mail].

At any time after March 19, 2021, the Commission may issue an order or orders cancelling the registrations of any or all of the registrants listed in the attached Appendix, upon the basis of the information stated above, unless an order or orders for a hearing on the cancellation shall be issued upon request or upon the Commission's own motion. Persons who requested a hearing, or who requested to be advised as to whether a hearing is ordered, will receive any notices and orders issued in this matter, including the date of the hearing (if ordered) and any postponements thereof. Any registrant whose registration is cancelled under delegated authority may appeal that decision directly to the Commission in accordance with rules 430 and 431 of the Commission's rules of practice (17 CFR 201.430 and 431).

ADDRESSES:

The Commission: [e-mail].

FOR FURTHER INFORMATION CONTACT:

Lawrence Pace, Senior Counsel, at 202-551-6999; SEC, Division of Investment Management, Investment Adviser Regulation Office, 100 F Street NE, Washington, DC 20549-8549.

For the Commission, by the Division of Investment Management, pursuant to delegated authority.²

J. Matthew DeLesDernier,

Assistant Secretary.

Appendix

SEC No.	Full legal name
801-80706	ATLANTIS ASSET MANAGEMENT INTERNATIONAL CORP.
801-80669	BLUE SHORES CAPITAL MANAGEMENT LLC.
801-107925	BRISTOL ADVISORS, LLC.
801-28037	BUSH O'DONNELL INVESTMENT ADVISORS, INC.
801-96240	CLINK SAVINGS INC.
801-80697	COPPIN COLLINGS LIMITED.
801-44774	EAST PACIFIC INVESTMENT CO INC.
801-108051	EMPEROR TREE CAPITAL LIMITED.
801-107673	ETHIKA INVESTMENTS, LLC.
801-107890	EVA CAPITAL MANAGEMENT LP.
801-57393	FINANCIAL WEST INVESTMENT GROUP, INC.
801-77028	FINLES N.V.
801-71707	FINVASIA FINANCIAL SERVICES PVT LTD.
801-79943	FOREFRONT CAPITAL ADVISORS, LLC.
801-66757	HARDING ADVISORY LLC.
801-61820	HIGH PERCH LLC.
801-61381	INDEPENDENT PORTFOLIO CONSULTANTS, INC.
801-50509	INTEGRATED WEALTH MANAGEMENT, INC.
801-108178	IPC PRIVATE WEALTH PARTNERS, LLC.
801-81034	KATZ FAMILY FINANCIAL ADVISORS, LLC.
801-115109	KEE MULTI FAMILY OFFICE CORP.
801-68831	LEBENTHAL ASSET MANAGEMENT, LLC.
801-79208	LEBENTHAL PARTNERS LLC.
801-78930	LEBENTHAL WEALTH ADVISORS, LLC.
801-57974	MARKETOCRACY CAPITAL MANAGEMENT LLC.
801-108510	MILLENNIUM CAPITAL PARTNERS LTD.
801-111687	MOONWALK CAPITAL LLC.
801-114916	POWERSCALE CAPITAL MANAGEMENT, LLC.
801-79356	QUANTMETRICS CAPITAL MANAGEMENT LLP.
801-36999	RENN CAPITAL GROUP, INC.
801-110578	RETIREMENT INCOME SECURITY SOLUTIONS, LLC.
801-78597	SAPPHIRE CAPITAL MANAGEMENT, LTD.
801-113600	SECOND NATURE INVESTMENTS LLC.
801-108811	SL2 INVESTMENTS LLC.
801-115294	SLATE CREEK CAPITAL, LLC.
801-112406	SOLARA INVESTMENT ADVISORS LLC.
801-81062	STARBOARD ASSET MANAGEMENT, INC.
801-107824	STAUFFER, ADAM WILLIAM.
801-112934	STOCKPITCH FINANCIAL CORPORATION.
801-47405	TONG ROBERT WAI.
801-117662	TRIDENT OS, LLC.
801-117680	UNICREDIT FINANCIAL SERVICES AND INVESTMENT ADVISOR.
801-113476	VENROTH PRINCIPAL MANAGEMENT.
801-74490	WEALTH MANAGEMENT, LLC.
801-110776	XENON PRIVATE EQUITY LTD.

Footnotes

1.  Rule 204-1 under the Act requires any adviser that is required to complete Form ADV to amend the form at least annually and to submit the amendments electronically through the Investment Adviser Registration Depository.

2.  17 CFR 200.30-5(e)(2).