Joseph F. Doody IV

SECURITIES EXCHANGE ACT OF 1934
Release No. 48870 / December 3, 2003

INVESTMENT ADVISERS ACT OF 1940
Release No. 2197 / December 3, 2003

Admin. Proc. File No. 3-11348

I.

The Securities and Exchange Commission ("Commission") deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted against Joseph F. Doody IV ("Respondent" or "Doody") pursuant to Sections 15(b) and 15B(c) of the Securities Exchange Act of 1934 ("Exchange Act") and Section 203(f) of the Investment Advisers Act of 1940 ("Advisers Act").

II.

In anticipation of the institution of these proceedings, Respondent has submitted an Offer of Settlement (the "Offer") which the Commission has determined to accept. Solely for the purpose of these proceedings and any other proceedings brought by or on behalf of the Commission, or to which the Commission is a party, and without admitting or denying the findings herein, except as to the Commission's jurisdiction over him and over the subject matter of these proceedings, and the findings contained in Section III.2 and III.4 below, which are admitted, Respondent consents to the entry of this Order Instituting Administrative Proceedings Pursuant to Sections 15(b) and 15B(c) of the Securities Exchange Act of 1934 and Section 203(f) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions ("Order"), as set forth below.

III.

On the basis of this Order and Respondent's Offer, the Commission finds that:

1. From February 1996 to February 2000, Doody was associated with Commerce Capital Markets, Inc., a broker-dealer, municipal securities dealer, and investment adviser registered with the Commission pursuant to Sections 15(b) and 15B(a) of the Exchange Act and Section 203(c) of the Advisers Act. From February 2000 to December 2002, Doody worked in Philadelphia, Pennsylvania as a registered representative for The GMS Group, LLC, a registered broker-dealer.

2. On November 18, 2003, a final judgment was entered by consent against Doody permanently enjoining him from violating Section 10(b) of the Exchange Act and Rule 10b-5 promulgated thereunder, in the civil action entitled Securities and Exchange Commission v. Joseph F. Doody IV, et al., Civil Action No. 02-2932, in the U.S. District Court for the Eastern District of Pennsylvania.

3. The Commission's complaint in Securities and Exchange Commission v. Joseph F. Doody IV, et al. alleged that Doody engaged in illegal insider trading in advance of the July 30, 1998 announcement that BetzDearborn Inc. and Hercules Inc. had agreed to merge. The complaint alleged that defendant Diane Neiley, an executive assistant at BetzDearborn, learned confidential information regarding the merger and tipped her then-boyfriend, Doody, who in turn tipped his father, Joseph F. Doody. According to the complaint, Doody purchased BetzDearborn common stock and call options that he sold after the merger announcement, realizing $240,953 in illegal profits. The complaint further alleged that after being tipped by his son, Joseph F. Doody bought BetzDearborn common stock that he sold after the announcement for unlawful profits of $30,813.

4. On December 5, 2002, Doody pled guilty to one count of insider trading in violation of Title 15 United States Code, Sections 78j(b) and 78ff, and one count of obstruction of justice in violation of Title 18 United States Code, Sections 1505 and 2, before the United States District Court for the Eastern District of Pennsylvania, in United States v. Joseph F. Doody, IV, Crim. No. 02-156. On March 27, 2003, a judgment in the criminal case was entered against Doody. He was sentenced to a prison term of eighteen months followed by two years of supervised release.

5. The counts of the criminal indictment to which Doody pled guilty alleged, inter alia, that Doody engaged in illegal insider trading in advance of the July 30, 1998 announcement that BetzDearborn Inc. and Hercules Inc. had agreed to merge and that Doody engaged in obstruction of justice by lying about his trades in a 1998 investigative interview with the staff of the Commission.

IV.

In view of the foregoing, the Commission deems it appropriate and in the public interest to impose the sanctions specified in Respondent Doody's Offer.

Accordingly, it is hereby ORDERED:

Pursuant to Sections 15(b)(6) and 15B(c)(4) of the Exchange Act and Section 203(f) of the Advisers Act, that Respondent Doody be, and hereby is barred from association with any broker, dealer, municipal securities 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.

By the Commission.