UNITED STATES OF AMERICA
                                     Before the
                         SECURITIES AND EXCHANGE COMMISSION


          SECURITIES EXCHANGE ACT OF 1934
          Release No. 40490 / September 28, 1998

          ADMINISTRATIVE PROCEEDING
          File No. 3-9635

          ______________________________
          In the Matter of              :
                                        :    ORDER MAKING FINDINGS AND IMPOSING
          CHRISTOPHER M. PEDERSEN       :    REMEDIAL SANCTIONS BY DEFAULT
                                        :    AGAINST RESPONDENT CHRISTOPHER M.
                                        :    PEDERSEN
          ______________________________:

               On  June  25,  1998,  the Securities and Exchange Commission
          (Commission) issued an Order  Instituting  Public  Administrative
          Proceeding (OIP) against Respondent Christopher M. Pedersen.  The
          OIP  ordered  Respondent  Pedersen  to  file  an  answer  to  the
          Commission's allegations within 20 days of service of the OIP, as
          provided  by  Rule 220 of the Commission's Rules of Practice,  17
          C.F.R.   201.220.   The Secretary of the Commission was unable to
          accomplish  service  by   certified  mail,  so  the  Division  of
          Enforcement (Division) retained  a  process server who personally
          served  Respondent  Pedersen  with  the  OIP   and   accompanying
          documents on August 12, 1998, in accordance with Rules 141(a) and
          200, 17 C.F.R.    201.141(a), .200.  Respondent Pedersen  did not
          file  an  answer  within  20 days of service, and has yet to file
          one.

               On  September 3, 1998,  the  Division  filed  a  Motion  for
          Default pursuant  to  Rules  155(a)  and  220(f),  17  C.F.R.  
          201.155(a), .220(f).  On September 11, 1998, I ordered Respondent
          Pedersen  to show cause why he should not be held in default, and
          why I should  not  sanction  him  pursuant  to Sections 15(b) and
          19(h) of the Securities Exchange Act of 1934 (Exchange Act).

               Respondent  Pedersen  is  in default because  he  failed  to
          answer the OIP.  He also failed  to  respond  to  the  Division's
          Motion  for  Default,  and  the  show  cause  order  I  issued on
          September 11, 1998.

               Accordingly,  I  find  that  the allegations in the OIP  are
          true:

               A.   Pedersen  was  licensed  as  a   securities  principal,
               registered  representative  and  general agent  (Series  39,
               Series  22  and Series 63, respectively),  from  1985  until
               1993, when his licenses were voluntarily terminated.

               B.  On April  21,  1998, a final judgment was entered by the
               United   States  District   Court,   Central   District   of
               California,   permanently  enjoining  Pedersen  from  future
               violations of Section 5(a), 5(c) and 17(a) of the Securities
               Act of 1933, and  Section 10(b) of the Exchange Act and Rule
               10b-5 promulgated thereunder  and assessing a $400,000 civil
               penalty against Pedersen.  SEC v. Pedersen, Civil Action No.
               95-6488 WJR (RNBx).

               C.  The Commission's Complaint  in  SEC  v. Pedersen alleged
               fraud in connection with the offer and sale  of unregistered
               securities,  primarily  in  the form of oil and gas  limited
               partnerships.   Specifically,  the  Complaint  alleged  that
               Pedersen made material  misrepresentations  and omissions in
               connection with the offer and sale of interests  in  various
               investment  programs  concerning,  among  other  things, the
               purchase  of  bonds purportedly backing oil and gas  limited
               partnership  investments,   the  use  of  funds  raised  for
               investment  programs  and  the financial  stability  of  the
               entities through which the investment programs were offered.
               Pedersen  also withdrew undisclosed  salary  "advances"  and
               "officer loans"  from  the entities and investment programs,
               and  did not disclose that  the  entities  were  in  serious
               financial decline from at least July of 1991.

               In addition  to  moving  for  an  order  of  default against
          Respondent Pedersen, the Division filed a request dated September
          22,  1998,  that  the  Commission  take  official notice  of  the
          Judgment entered by the court in SEC v. Pedersen,  the  Complaint
          filed  in that action, and the contents of both the Judgment  and
          the Complaint.  I hereby take official notice of the Judgment and
          Complaint in SEC v. Pederson and the contents thereof pursuant to
          Rule 323, 17 C.F.R.  201.323.

               In  view  of the foregoing, I find it in the public interest
          to sanction Pedersen  pursuant to Sections 15(b) and 19(h) of the
          Exchange Act.

               Accordingly,  it  is  hereby  ORDERED  that  Christopher  M.
          Pedersen is barred from  association  with any broker, dealer, or
          member of a national securities exchange or registered securities
          association.

               A  hearing  in this matter is currently  scheduled  to  take
          place on September 30, 1998.  The Division has moved for an order
          vacating this hearing date.  I hereby ORDER that the hearing date
          is vacated.

                                        ____________________________
                                        Lillian A. McEwen
                                        Administrative Law Judge