UNITED STATES OF AMERICA 

 Before the 

 SECURITIES AND EXCHANGE COMMISSION 

SECURITIES EXCHANGE ACT OF 1934 

Release No. 61653 / March 5, 2010 

ADMINISTRATIVE PROCEEDING 

File No. 3-13199 

 

In the Matter of 

CORNERSTONE CAPITAL 

MANAGEMENT, INC., and 

LAURA JEAN KENT, 

Respondents. 

ORDER APPROVING PLAN AND 

APPOINTING A PLAN 

ADMINISTRATOR 

On March 20, 2009, the Securities and Exchange Commission (“Commission”) entered an 

Order instituting settled administrative and cease-and-desist proceedings against Cornerstone 

Capital Management, Inc. and Laura Jean Kent (collectively “Respondents”) in this matter 

(“Order”). In the Matter of Cornerstone Capital Management, Inc., and Laura Jean Kent, 

Investment Advisers Act Rel. No. 2855, Admin. Proc. File No. 3-13199 (Mar. 20, 2009). In the 

Order, the Commission authorized the disgorgement of $335,758.00 by Respondents, for 

distribution to individuals and entities that invested with Respondents in impaired programs (as 

described in the Order) and paid assets-under management fees on the impaired investments. 

The Order provided that the disgorgement was to be distributed pursuant to a distribution plan (the 

“Distribution Plan”) developed by Respondents in consultation with the Division of Enforcement. 

 On December 18, 2009, the Commission published a “Notice of Proposed Plan of 

Distribution and Opportunity for Comment” (“Notice”) pursuant to Rule 1103 of the 

Commission’s Rules on Fair Fund and Disgorgement Plans, 17 C.F.R. §201.1103. (Exchange 

Act Release No. 61208). The Notice advised all interested parties that they may print a copy of 

the Distribution Plan from the Commission’s website, https://www.sec.gov, or by submitting a 

written request to Robert L. Mitchell, Trial Counsel, United States Securities and Exchange 

Commission, 44 Montgomery Street, Suite 2600, San Francisco, CA 94104. 

 The Notice also advised all persons desiring to comment on the Distribution Plan that 

they may submit their comments, in writing, no later than 30 days from the date of the Notice by 

sending a letter to the Office of the Secretary, United States Securities and Exchange 

Commission, 100 F Street, N.E., Washington, DC 20549-1090; by using the Commission’s 

Internet comment form (http://www.sec.gov/litigation.admin.shtml); or by sending an e-mail to 
2

rule-comments@sec.gov. The Commission received no comments on the Distribution Plan and 

no modification has been made to the Distribution Plan since its publication.1

The Distribution Plan provides for distribution of the disgorgement amount to individuals 

and entities that invested with Respondents in impaired programs and paid assets-under 

management fees on the impaired investments. The Distribution Plan describes the procedures to 

be used to identify the harmed investors that will receive distributions. The Distribution Plan 

further describes the procedures to be used to calculate the amounts to be paid to the harmed 

investors and to distribute those amounts to the harmed investors. Eligible harmed investors will 

not be required to make a claim or submit documentation to establish their eligibility. 

The Distribution Plan also proposes Mr. Mitchell as the Plan Administrator and sets 

forth, among other things, procedures for distributing funds from the disgorgement amount to 

investors; procedures for the administration of the distribution, including provisions for filing tax 

returns; and a proposed timeframe for the termination of the Distribution Plan. 

Because Mr. Mitchell is a Commission employee, no bond is required pursuant to Rule 

1105(c). 

The staff requests that the Commission approve the Distribution Plan and appoint Mr. 

Mitchell as the Plan Administrator. 

Accordingly, pursuant to Rule 1104, it is hereby ORDERED that the Distribution Plan is 

approved. 

 It is hereby ORDERED, pursuant to Rule 1105(a), that Mr. Mitchell is appointed as the 

Plan Administrator in accordance with the terms of the Distribution Plan. 

 For the Commission, by its Secretary, pursuant to delegated authority. 

 

Elizabeth M. Murphy 

 Secretary 

 

1 Some minor typographical and administrative changes have been made to the proposed Plan for clarity and 

accuracy.