DTD to Schema converter

Hi,

I am working on a converter to convert DTD declarations to Schema
declarations.   After reading the XML spec., I am still not clear what's

the expected result for the following DTD declarations:
   <!ELEMENT abc ANY>
For this declaration, it does NOT have associated attribute type
declarations with element type "abc".

For a validating processor, does this mean:
    1) element "abc" can have any attributes (i.e. wildcard attributes
in Schema), or
    2) element "abc" cannot have any attributes?

Note that the only thing I read in XML spec. is:
   All attributes for which no declaration has been read should be
treated
   by a non-validating processor as if declared CDATA.

Thx,

-Stanley