**Release:    ��������������������    #4300-99****For Release:    ������������    August 10, 1999**

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**CFTC FILES AN ENFORCEMENT ACTION    AGAINST AND ACCEPTS OFFER OF SETTLEMENT FROM WOLCOTT & LINCOLN L.L.C.    AND DAVID GIBSON**

**CFTC Finds That Wolcott & Lincoln, An FCM, Improperly    Handled Customer Money, Violated Recordkeeping Requirements, Filed False    Reports and Failed To Supervise Diligently; Gibson, As Manager of Wolcott    & Lincoln, Is Also Found Liable.**

WASHINGTON - The Commodity Futures Trading Commission (CFTC) announced    today that it issued an    order instituting and simultaneously settling an administrative    proceeding against **Wolcott & Lincoln Futures, L.L.C**.,    a registered futures commission merchant (FCM), and **David    Gibson**, of Shawnee Mission, Kansas, the manager of Wolcott &    Lincoln.

The CFTC order finds that Wolcott & Lincoln, formerly known as    Wolcott & Lincoln Futures, Inc., mishandled customer funds; willfully    filed inaccurate and improperly executed reports with the CFTC; violated    CFTC recordkeeping requirements; and breached its duty to supervise    diligently the handling of customer funds. The order also finds Gibson    liable for Wolcott & Lincoln's violations. The CFTC's order, among    other things, revokes Wolcott & Lincoln's FCM registration, imposes a    $50,000 civil monetary penalty and requires Gibson to comply with extensive    undertakings. Wolcott & Lincoln and Gibson consented to the issuance of    the order without admitting or denying the findings contained in it.     According to the CFTC's order, in January 1995, Wolcott & Lincoln    transferred its customer accounts to LIT Division of First Options of    Chicago, Inc. (FOC), a Chicago firm registered with the CFTC as a FCM. FOC    formed a Kansas City branch office (W&L Division) which was staffed by    former Wolcott & Lincoln employees and handled the former Wolcott &    Lincoln customer accounts, according to the order. Wolcott & Lincoln    survived as a legal entity and a registered FCM.     The CFTC's order finds that although Wolcott & Lincoln purported to be    inactive, Wolcott & Lincoln's bank accounts continued to be used to    pass new funds from customers to the trading accounts that had been    transferred to FOC, and that in 1995, Wolcott & Lincoln ignored proper    procedures and regulatory requirements with respect to the segregation and    transfer of customer funds, allowing customer funds to be commingled with    the funds of others, in violation of Section 4d(2) of the CEA and    Commission Regulation 1.20; willfully filed with the CFTC inaccurate and    improperly executed forms which were supposed to identify funds held in    segregation for customers, in violation of Section 6(c) of the CEA and    Commission Regulation 1.10; and failed to maintain required segregation    records and other records and failed to issue commodity statements to    customers, in violation of Section 4g of the CEA and Commission Regulations    1.10, 1.18, 1.31, 1.32 and 1.33. Further, the CFTC order finds Gibson    liable for all of Wolcott & Lincoln's violations, as a controlling    person of that firm, pursuant to Section 13(b) of the CEA.     The CFTC's order also finds that, in 1994 and 1995, Wolcott & Lincoln    and Gibson failed to supervise diligently Wolcott & Lincoln's    employees, agents and officers, in violation of Commission Regulation    166.3, by, among other things, failing to develop or implement an adequate    supervisory system, particularly as it relates to handling customer money.    The order further finds that Gibson similarly did not supervise diligently    FOC's W&L Division.     As consented to, the CFTC's order:     1.�������� directs Wolcott &    Lincoln and Gibson to cease and desist from further violations of the CEA    and Commission Regulations;

2.�������� orders them to pay    jointly and severally a civil monetary penalty in the amount of $50,000;     3.�������� evokes the FCM    registration of Wolcott & Lincoln; and     4.�������� requires Gibson to    comply with his undertakings to:     ����������� --    �������� close and permanently    discontinue the FCM business of Wolcott & Lincoln;     ����������� --    �������� have E.D. & F. Man    International, Inc., the current owner of the W&L Division, which    remains under Gibson's management, review and, if necessary, further    develop the policies, procedures and organizational structure of the    W&L Division to ensure that they are reasonably designed to deter,    detect, discipline and correct conduct of the type that was found in the    CFTC's order to violate the CEA and the Commission's Regulations;     ����������� --    �������� develop written policies    and procedures and a defined organizational structure for any FCM or    introducing broker Gibson seeks to register or of which Gibson becomes a    principal or manager in the future; and     ����������� --    �������� attend eight hours of    formal training this year and next regarding the regulatory obligations of    branch offices and FCMs.