UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC ADMINISTRATIVE RELEASE NO. 34-49862, 40-2249 DATED JUNE 15, 2004; THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION" OR "SEC") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTION 203(F) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST SCOTT FINE ("FINE" OR "RESPONDENT").

Order

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IT IS ORDERED PURSUANT TO SECTION 15(B)(6) OF THE EXCHANGE ACT AND SECTION 203(F) OF THE ADVISERS ACT, THAT THE RESPONDENT BE, AND HEREBY IS, BARRED FROM ASSOCIATION WITH ANY BROKER, DEALER, OR INVESTMENT ADVISER; ANY REAPPLICATION FOR ASSOCIATION BY THE RESPONDENT WILL BE SUBJECT TO THE APPLICABLE LAWS AND REGULATIONS GOVERNING THE REENTRY PROCESS, AND REENTRY MAY BE CONDITIONED UPON A NUMBER OF FACTORS, INCLUDING, BUT NOT LIMITED TO, THE SATISFACTION OF ANY OR ALL OF THE FOLLOWING: (A) ANY DISGORGEMENT ORDERED AGAINST THE RESPONDENT, WHETHER OR NOT THE COMMISSION HAS FULLY OR PARTIALLY WAIVED PAYMENT OF SUCH DISGORGEMENT; (B) ANY ARBITRATION AWARD RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER; (C) ANY SELF-REGULATORY ORGANIZATION ARBITRATION AWARD TO A CUSTOMER, WHETHER OR NOT RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER; AND (D) ANY RESTITUTION ORDER BY A SELF-REGULATORY ORGANIZATION, WHETHER OR NOT RELATED TO THE CONDUCT THAT SERVED AS THE BASIS FOR THE COMMISSION ORDER.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC LITIGATION RELEASE NO. 18600, DATED FEBRUARY 27, 2004: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION" OR "SEC") ANNOUNCED THAT ON FEBRUARY 26, 2004, IT FILED AN EMERGENCY ACTION TO HALT AN ALLEGED HEDGE FUND FRAUD CONDUCTED BY A COMPANY, ITS TWO PRINCIPALS, ONE MR. SCOTT FINE ("FINE") AND ANOTHER INDIVIDUAL OTHER TWO HEDGE FUNDS. ACCORDING TO THE SEC'S COMPLAINT, SINCE AT LEAST 2000, PRINCIPALS HAVE USED THEIR COMPANY, ADVISORS, TO RAISE APPROXIMATELY $10 MILLION FROM ABOUT 100 INVESTORS NATIONWIDE AND ABROAD THROUGH INVESTMENTS IN THE HEDGE FUNDS. THE SEC ALLEGES THAT THE REPRESENTATIONS MADE BY THE ADVISORS AND PRINCIPALS TO THE HEDGE FUNDS' INVESTORS ABOUT THE EVER-INCREASING PROFITS AND NET ASSET VALUES OF HEDGE FUNDS WERE COMPLETELY FALSE. ACCORDING TO THE SEC, THE INVESTMENTS MADE BY PRINCIPALS ON BEHALF OF THE HEDGE FUNDS, WHICH CONSIST MOSTLY OF SPECULATIVE OPTIONS TRADING, HAVE LOST MILLIONS OF DOLLARS. THE SEC ALSO ALLEGES THAT PRINCIPALS CHARGED INVESTORS FRAUDULENT FUND PERFORMANCE FEES BASED ON THE FICTITIOUS GAINS IN THE VALUES OF THE TWO HEDGE FUNDS AND ADDITIONAL UNDISCLOSED "ADVISORY FEES." THE SEC CHARGES DEFENDANTS WITH VIOLATING SECTION 17(A) OF THE SECURITIES ACT OF 1933, SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER, AND ALSO CHARGES WITH VIOLATING SECTIONS 206(1) AND 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT).

Judgment Rendered

Monetary/Fine

$1,180,262.00

Disgorgement/Restitution

Cease and Desist/Injunction

SEC LITIGATION RELEASE NO. 18812 DATED JULY 29, 2004; THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT ON MAY 25, 2004, THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF FLORIDA ENTERED A JUDGMENT OF PERMANENT INJUNCTION AND OTHER RELIEF AGAINST DEFENDANT SCOTT FINE ("FINE"). IN ADDITION TO INJUNCTIVE RELIEF, THE JUDGMENT PROVIDES FOR DISGORGEMENT AND THE IMPOSITION OF CIVIL PENALTIES IN AMOUNTS TO BE REACHED BY AGREEMENT OF THE PARTIES AND/OR BY THE COURT UPON THE SEC'S MOTION. SEC LITIGATION RELEASE NO. 19611, DATED MARCH 16, 2006: THE SECURITIES AND EXCHANGE COMMISSION ANNOUNCED THAT ON FEBRUARY 6, 2006, THE MIDDLE DISTRICT OF FLORIDA, ENTERED FINAL JUDGMENT SETTING DISGORGEMENT AND CIVIL PENALTIES AGAINST SCOTT FINE. AFTER THE COURT CONDUCTED AN EVIDENTIARY HEARING ON JANUARY 17, 2006, IT ORDERED FINE TO PAY WITHIN THIRTY DAYS $1,180,262.00 IN DISGORGEMENT, PLUS PREJUDGMENT INTEREST OF $69,439.00, AND A $1,180,262.00 CIVIL PENALTY.

NASD

NASD RULES 2110, 8210 - RESPONDENT SENT PARTNERS IN A LIMITED PARTNERSHIP E-MAILS THAT SHOWED INFLATED PARTNERSHIP VALUATIONS AND CAUSED SCHEDULE K-1 PARTNERSHIP TAX DOCUMENTS TO BE ISSUED TO PARTNERS THAT WERE INACCURATE; A MEMBER FIRM, ACTING THROUGH FINE, PROVIDED INACCURATE INFORMATION TO NASD REGARDING TRADES LISTED ON A SCHEDULE OF TRANSACTIONS THAT DID NOT APPEAR ON ISSUER ACCOUNT STATEMENTS; AND FAILED TO RESPOND TO NASD REQUESTS FOR DOCUMENTS AND TESTIMONY.

Acceptance, Waiver & Consent(AWC)

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WITHOUT ADMITTING OR DNEYING THE ALLEGATIONS, FINE CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE, HE IS BARRED FROM ASSOCIATION WITH ANY NASD MEMBER IN ANY CAPACITY.

NASD REQUESTED INFORMATION ABOUT VALUATIONS OF A LIMITED PARTNERSHIP AND PERSONAL INFORMATION ABOUT LIMITED PARTNERS OF A PRIVATE LIMITED PARTNERSHIP DURING A PERIOD OF TIME WHEN I WAS NOT SUBJECT TO NASD JURISDICTION. I PROVIDED INFORMATION ABOUT THE VALUATIONS THAT INADVERTENTLY CONTAINED SOME ERRORS THAT I LATER CORRECTED. AFTER RESPONDING TO NUMEROUS REQUESTS FOR INFORMATION OVER 2 YEARS, I REALIZED THAT NASD WAS REQUESTING THE SAME INFORMATION THAT I HAD PREVIOUSLY PROVIDED TO THEM. NASD FAILED TO ACKNOWLEDGE THAT THEIR REQUESTS WERE DUPLICATIVE AND THEREFORE ALLEGED THAT I FAILED TO PROVIDE THEM WITH REQUESTED INFORMATION.