UNITED STATES OF AMERICA
                            Before the
                SECURITIES AND EXCHANGE COMMISSION


Securities Act of 1933
Release No.  7256 / January 16, 1996     

Securities Exchange Act of 1934
Release No. 36713 / January 16, 1996    

Accounting and Auditing Enforcement
Release No.   753 / January 16, 1996    

Administrative Proceeding
File No. 3-8662
__________________________________
                                  :
In the Matter of                  :
                                  :     CEASE AND DESIST 
                                  :     ORDER AND
                                  :     OPINION AND ORDER
Ronald Effren,                    :     PURSUANT TO RULE 2(e)
Andrew S. Fink, and               :     OF THE COMMISSION'S  
Lee L. Engel,                     :     RULES OF PRACTICE        
                                  :      
          Respondents.            :      
                                  :       
                                  :  
----------------------------------
                                I.

     In connection with these administrative proceedings pursuant
to Section 8A of the Securities Act of 1933 ("Securities Act")
and Section 21C of the Securities Exchange Act of 1934 ("Exchange
Act") and pursuant to former Rules 2(e)(1)(i), (ii) and (iii) of
the Commission's Rules of Practice, Ronald Effren ("Effren"),
Andrew S. Fink ("Fink"), and Lee L. Engel ("Engel") have
submitted Offers of Settlement ("Offer") to the Commission, which
the Commission has determined to accept. -[1]-  Solely for the
purpose of these proceedings, and any other proceeding brought by
or on behalf of the Commission, or in which the Commission is a
party, and without admitting or denying any of the findings or
conclusions contained herein, except that they admit jurisdiction
of the Commission over them and over the subject matter of this
proceeding, Effren, Fink and Engel consent to the issuance of
this Cease and Desist Order and Opinion and Order Pursuant to
Rule 2(e) of The Commission's Rules of Practice ("Opinion and
Order").




                               II.


                                             
--------- FOOTNOTES ---------

-[1]-     The Order Instituting Cease and Desist Proceedings and
          Notice of Hearing Pursuant to Section 8A of the
          Securities Act of 1933 and Section 21C of the
          Securities Exchange Act of 1934 and Order Instituting
          Proceedings Pursuant to Rule 2(e) of the Commission's
          Rules of Practice in this matter was issued on April 7,
          1995.  

-------------------- BEGINNING OF PAGE #2 -------------------

     On the basis of this Opinion and Order, and the Offers
submitted by Effren, Fink, and Engel, the Commission makes the
following findings:-[2]-

     1.   Tradux Corp. ("Tradux"), a Delaware corporation,
completed a blank check public offering in October 1987. 
Tradux's common stock was traded in the over-the-counter market
and was quoted in the National Quotation Bureau, Inc.'s "Pink
Sheets" through mid-1991.  On February 27, 1990, Tradux
registered its common stock with the Commission pursuant to
Section 12(g) of the Exchange Act.

     2.   Effren, age 67, was the treasurer, chief financial
officer and a director of Tradux from June 30, l989 through
September 1, 1991.   Effren is not a certified public accountant
("CPA").  From in or about January 1986 through on or about June
30, 1989, Effren was the treasurer and a director of Advisors
Capital Technology Corp. ("Advisors").

     3.   Fink, age 50, resides in Centerville, Massachusetts and
has never been a CPA.

     4.   Engel, 58 years old, is licensed as a CPA in the State
of Florida and operates as a sole practitioner.

     5.   Advisors was incorporated in 1984 and conducted a blank
check offering in 1986.  Advisors was engaged in numerous
businesses, including the development of two language translation
computer software programs which it acquired in 1988 through
International Translation Systems, Inc. ("ITS"), then a newly
formed wholly owned subsidiary of Advisors.

     6.   From January 1989 to February 1990, Tradux was required
to file periodic reports pursuant to Section 15(d) of the
Exchange Act, and from March 1990 to the present, Tradux has been
required to file periodic reports pursuant to Section 13(a) of
the Exchange Act.  Both sections require that Tradux include in
its periodic reports financial statements prepared in accordance
with Regulation S-X.  

     Violations of the Antifraud and Reporting Provisions 
     by Tradux

     7.   Section 4-01(a) of Regulation S-X requires that
financial statements filed with the Commission comply with
generally accepted accounting principles ("GAAP").  GAAP required
that Tradux's acquisition of International Translation Systems,
Inc. ("ITS") on June 30, 1989 be accounted for at historical cost
in a manner similar to that in "pooling of interests" accounting
because Tradux and Advisors, the sole stockholder of ITS, were
entities under common control.  Effren made and caused Tradux to
make material misrepresentations and omissions of material facts
in connection with its accounting for the acquisition of ITS in
its June 30, 1989 interim balance sheet, in that Tradux used the
purchase method of accounting rather than the historical cost
method of accounting mandated by GAAP.  Tradux's June 30, 1989
                                             
--------- FOOTNOTES ---------

-[2]-     Any findings contained herein are solely for the
          purpose of these proceedings and are not binding on any
          other person or entity named as a respondent in any
          other proceeding.

                                        -   -2

-------------------- BEGINNING OF PAGE #3 -------------------

interim balance sheet was included in Tradux's June 30, 1989
quarterly report on Form 10-Q, a Current Report on Form 8-K dated
June 30, 1989, as amended (the "Form 8-K"), and the Post-
Effective Amendment, each filed with the Commission. Tradux's
improper accounting for the ITS acquisition similarly affected
all subsequent financial statements filed by Tradux with the
Commission.  

     8.   Use of the purchase method of accounting caused Tradux
to report goodwill as an asset which overstated Tradux's June 30,
1989 assets by $345,310; and caused Tradux to overvalue the
500,000 Tradux shares issued to Advisors, as partial
consideration for ITS.  As a consequence, Tradux's June 30, 1989
shareholders' equity was similarly overstated by $345,310 (the
amount of goodwill).

     9.   By reason of Tradux's acquisition of ITS, Tradux
acquired the ownership rights to ITS's computer software
programs.  GAAP requires that, to the extent computer software is
not "technologically feasible" at the time of acquisition, the
costs thereof shall be expensed as research and development
costs.   On June 30, 1989, the date of the acquisition, and
thereafter, the computer programs acquired by Tradux were not
technologically feasible within the meaning of GAAP. 
Nevertheless, Tradux improperly recorded the computer software
programs on its June 30, 1989 interim balance sheet as assets in
the aggregate amount of $973,282, which caused Tradux to
overstate its June 30, 1989 assets and shareholder's equity by
$973,282.  Tradux also overstated its June 30, 1989 shareholders'
equity by $973,282.  Tradux's June 30, 1989 interim balance sheet
was included in Tradux's June 30, 1989 Form 10-Q, the Form 8-K,
and the Post-Effective Amendment, each filed with the Commission.

Tradux's improper accounting for the computer software programs
similarly affected all subsequent financial statements filed by
Tradux with the Commission.    

     10.  On December 28, 1989, Tradux entered into a technology
licensing agreement with Coral Companies.  GAAP requires that
revenue may not be recognized until an exchange has occurred, the
earnings process is complete and the collection of the sale price
is reasonably assured.  Recognition of revenue involves
consideration of two factors: (i) being realized or realizable,
and (ii) being earned.  Tradux improperly recognized $550,000 of
revenue in connection with a licensing agreement dated December
28, 1989, entered into with Coral (the "Coral Agreement"). 
Pursuant to the Coral Agreement, Tradux agreed to license to
Coral the marketing rights to the computer software programs in
exchange for a cash payment, 500,000 shares of Coral common
stock, and certain royalty payments.  However, the licensing was
contingent upon the development by Tradux of a 12,000 word
vocabulary for the computer programs by August 1, 1990, with a
ninety-day extension to November 1, 1990.  The parties agreed
that Coral would have the right to cancel the Agreement and
Tradux would be required to return all consideration to Coral if
the technology was not developed by Tradux as agreed by November
1, 1990.  Pending development of the technology, the Coral stock
certificates were held in an escrow account.  Tradux's
recognition of revenue with respect to the Coral Agreement as of
December 31, 1989 was improper in light of the fact that the
obligations on Tradux were far from complete as of such date. 
Tradux reported no other revenues as of December 31, 1989.    


                                        -   -3

-------------------- BEGINNING OF PAGE #4 -------------------

     Effren's Conduct

     11.  From in or about June 1989 through in or about April
1991, Effren violated Section 17(a) of the Securities Act and
Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, in
that he, directly and indirectly, by the use of any means and
instruments of transportation and communication in interstate
commerce, any means and instrumentalities of interstate commerce,
and of the mails, and of any facility of any national securities
exchange, in the offer and sale, and in connection with the
purchase and sale of any security, employed devices, schemes, and
artifices to defraud; obtained money and property by means of,
and otherwise made, untrue statements of material facts and
omitted to state material facts necessary in order to make the
statements made, in light of the circumstances under which they
were made, not misleading; and engaged in transactions, acts,
practices and courses of business which operated and would
operate as a fraud and deceit upon persons, in that he made
material misrepresentations and omitted to state material facts
in Tradux's financial statements filed with the Commission as
part of Tradux's June 30, 1989 Form 10-Q, the Form 8-K, the Post-
Effective Amendment, the September 30, 1989 Form 10-Q, the 1989
Form 10-K, the March 31, June 30, and September 30, 1990 Forms
10-Q, the 1990 Form 10-K, and the March 31 and June 30, 1991
Forms 10-Q (collectively, the "Exchange Act Reports").  As
described above, such financial statements, which were prepared
by Effren, contained material misstatements and omissions of
material facts relating to Tradux's accounting for (i) the
acquisition of ITS, (ii) the computer software programs, and
(iii) the Coral Agreement.

     12.  From in or about June 1989 through in or about April
1991, Effren caused Tradux to violate Sections 13(a) and 15(d) of
the Exchange Act and Rules 12b-20, 13a-1, 13a-13, 15d-1, 15d-11,
and 15d-13 thereunder as described in paragraph 11 above.  

     Violations by Fink

     13.  Fink allegedly audited the January 31, 1989 year-end
financial statements of ITS, which was acquired by Tradux in June
1989.  Although he represented himself to be a CPA at the time of
such audit, Fink has never been a CPA.    

     14.  From in or about June 1989 through in or about October 
1989, Fink willfully violated Section 17(a) of the Securities Act
and Section 10(b) of the Exchange Act and Rule 10b-5 thereunder,
in that he directly and indirectly, by the use of any means and
instruments of transportation and communication in interstate
commerce, any means and instrumentalities of interstate commerce,
and of the mails, and of any facility of any national securities
exchange, in the offer and sale, and in connection with the
purchase and sale of any security, employed devices, schemes, and
artifices to defraud; obtained money and property by means of,
and otherwise made, untrue statements of material facts and
omitted to state material facts necessary in order to make the
statements made, in light of the circumstances under which they
were made, not misleading; and engaged in transactions, acts,
practices and courses of business which operated and would
operate as a fraud and deceit upon persons, in that Fink falsely
held himself out as a certified public accountant in connection
with his alleged audit of the January 31, 1989 year-end ITS
financial statements and such financial statements and Fink's

                                        -   -4

-------------------- BEGINNING OF PAGE #5 -------------------

audit report thereon (the "ITS Audit Report") were included in a
Post-Effective Amendment and in a Form 8-K dated June 30, 1989,
each filed with the Commission by Tradux.  The inclusion of the
ITS financial statements and the ITS Audit Report in Tradux's
public filings violated Regulation S-X, which provides that the
"Commission will not recognize any person as a certified public
accountant who is not duly registered and in good standing as
such under the laws of the place of his residence or principal
office."  

     15.  Accordingly, pursuant to Rule 2(e)(1)(i) and (iii) of
the Commission's Rules of Practice, the Commission has determined
that Fink does not possess the requisite qualifications to
represent others, and that he willfully violated the provisions
of the federal securities laws set forth above.

     Improper Professional Conduct by Engel

     16.  On or about February 12, 1990, Tradux filed with the
Commission a Form 10-K that contained financial statements for
the year ended December 31, 1989.  Engel issued an unqualified
audit report on Tradux's financial statements for the year ended
December 31, 1989, stating that his audit of such financial
statements was conducted in accordance with generally accepted
auditing standards ("GAAS") and that Tradux's financial
statements were, in all material respects, fairly presented in
conformity with generally accepted accounting principles
("GAAP").  Engel's audit report was included in Tradux's Form 10-
K for the year ended December 31, 1989.

     17.  On or about April 1, 1991, Tradux filed with the
Commission a Form 10-K that contained financial statements for
the year ended December 31, 1990.  This Form 10-K contained an
unqualified audit report issued by Engel on those financial
statements, stating that he had conducted his audit in accordance
with GAAS and that Tradux's financial statements were, in all
material respects, fairly presented in conformity with GAAP.


Engel's Failure to Perform the Audits in Accordance with GAAS

     Engel's Audit Reports Improperly Stated that Tradux's
Financial Statements Were Presented in Conformity with GAAP

     18.  Statement on Auditing Standards ("SAS") No. 1,
promulgated by the American Institute of Certified Public
Accountants ("AICPA"), requires that an audit report state
whether the financial statements are presented in conformity with
GAAP.  AU Section 110.01.  The audit reports issued and signed by
Engel, and included in Tradux's 1989 and 1990 Forms 10-K, stated
that Tradux's financial statements had been presented in
conformity with GAAP, when, in fact, they were not.

     19.  As discussed below, Tradux improperly accounted for the
acquisition of International Translation Systems, Inc. ("ITS")
from an affiliate in June 1989 and Tradux improperly recognized
revenue from a technology licensing agreement with Coral
Companies ("Coral") in December 1989.  As a result, Tradux
materially overstated its assets, shareholders' equity and
revenues in financial statements filed with the Commission.  



                                        -   -5

-------------------- BEGINNING OF PAGE #6 -------------------

     20.  Specifically, on June 30, 1989, Tradux acquired from
Advisors all of the outstanding shares of the common stock of ITS
in exchange for 500,000 shares of Tradux common stock, a cash
payment of $125,000, and a percentage of any future royalty
payments received, if any, in connection with ITS's software
programs.  GAAP required that Tradux's acquisition of ITS be
accounted for at historical cost in a manner similar to that in
"pooling of interests" accounting because Tradux and Advisors
were entities under common control.  However, Tradux improperly
accounted for the ITS acquisition by using the purchase method of
accounting.  The use of the purchase method of accounting caused
Tradux to report goodwill as an asset which overstated Tradux's
December 31, 1989 and 1990 assets by $345,310, and caused Tradux
to overvalue the 500,000 Tradux shares that it had issued to
Advisors as partial consideration for ITS.  As a consequence,
Tradux's December 31, 1989 and December 31, 1990 shareholders'
equity was similarly overstated by $345,310.

     21.  By reason of Tradux's acquisition of ITS, Tradux
acquired the ownership rights to ITS's computer software
programs.  GAAP requires that, to the extent computer software is
not "technologically feasible" at the time of acquisition, the
costs thereof be expensed as research and development costs.   On
June 30, 1989, the date of the acquisition, and thereafter, the
computer programs acquired by Tradux were not technologically
feasible as within the meaning of GAAP.  Nevertheless, Tradux
improperly recorded the computer software programs on its
December 31, 1989 and December 31, 1990 balance sheets as assets
in the aggregate amount of $973,282.  Tradux similarly overstated
its December 31, 1989 and December 31, 1990 shareholders' equity
by $973,282.

     22.  Pursuant to the December 28, 1989 agreement with Coral,
Tradux agreed to license to Coral the marketing rights to its
computer software programs in exchange for a cash payment,
500,000 shares of Coral common stock, and certain royalty
payments.  However, the licensing agreement was contingent upon
the development by Tradux of a 12,000 word vocabulary for the
computer programs by August 1, 1990, with a ninety-day extension
to November 1, 1990.  The parties agreed that Coral would have
the right to cancel the agreement and Tradux would be required to
return all consideration to Coral if the technology was not
developed by Tradux as agreed by November 1, 1990.  Pending
development of the technology, the stock certificates issued by
Coral in consideration for the licensing rights were held in an
escrow account.

     23.   Tradux improperly recognized $550,000 of revenue from
the licensing agreement with Coral during the year ended December
31, 1989.  GAAP provides that revenue is to be recognized when an
exchange has occurred, the earnings process is complete and the
collection of the sale price is reasonably assured.  The
recognition of revenue involves consideration of two factors: (i)
whether revenue is realized or realizable, and (ii) whether it is
earned.  Tradux's recognition of revenue in 1989 resulting from
its agreement with Coral was improper because of the unfulfilled
contingency in the agreement to produce a marketable product by
November 1, 1990.  Since Tradux's obligations pursuant to its
agreement with Coral were far from complete as of December 31,
1989, the revenue that Tradux recognized from its agreement with
Coral was neither realized or realizable, nor earned as of such


                                        -   -6

-------------------- BEGINNING OF PAGE #7 -------------------

date.  Tradux reported no other revenue during the year ended
December 31, 1989.    

     Inadequate Planning

     24.  GAAS provides that an audit must be adequately planned.

AU Section 311.01.  Audit planning involves developing an overall
strategy for the expected conduct and the scope of the audit.  AU
Section 311.03.  In planning the audit, the auditor should
consider the nature, extent, and timing of work to be performed
and should prepare a written audit program.  AU Section 311.05. 
The audit program should set forth the audit procedures that the
auditor believes are necessary to accomplish the objectives of
the audit.  Id.  Engel's workpapers do not include a written
audit program and otherwise fail to indicate that the audit was
adequately planned.  See In Re James C. Andrus, C.P.A., Exchange
Act Release 31267,  AAER No. 424 (September 30, 1992) (adequately
planned audit engagements include a written audit program or
strategy of expected conduct).

     Failure to Gather Sufficient Competent Evidential Matter in
the Audits of the December 31, 1989 and the December 31, 1990
Financial Statements 

     25.  An auditor must obtain sufficient competent evidential
matter to afford a reasonable basis for an opinion regarding the
financial statements under audit.  AU Section 326.01.  Evidence
obtained from an independent source outside the entity which is
being audited provides greater assurance of reliability than
evidence obtained from the entity being audited.  AU Section
326.19.a.  The confirmation of accounts receivable is a generally
accepted auditing procedure.   AU Section 331.01, (superseded by
AU Section 330.34).  

     26.  With respect to Tradux's accounting for the acquisition
of ITS, Engel failed to determine whether Advisors and Tradux
were entities under common control.  Similarly, with respect to
the recording of the computer software programs as assets, Engel
knew that the computer software programs were in a developmental
stage.  However, Engel failed to accumulate evidence sufficient
to ascertain whether the computer software programs were
technologically feasible, as defined by GAAP.  Accordingly, Engel
was unable to assess the appropriateness of Tradux's accounting
for the acquisition of ITS or of its computer software programs. 
Finally, Engel failed to substantiate Tradux's method of
accounting for the Coral licensing agreement with available
documentary evidence, such as the agreement, and he failed to
confirm the Tradux receivable from Coral at December 31, 1989.

     Improper Audit Reports

     27.  An auditor's report is required to state whether the
audit was conducted in accordance with GAAS and that the
financial statements were prepared in conformity with GAAP.  AU
Section 508.08.  Engel failed to obtain sufficient competent
evidential matter in the course of auditing Tradux's December 31,
1989 and December 31, 1990 financial statements.  An inability to
obtain sufficient competent evidential matter constitutes a
restriction on the scope of the audit which may require an
auditor to disclaim or qualify an opinion.  AU Section 508.17.  A
disclaimer of opinion is appropriate when the auditor has not
performed an audit in sufficient scope to form an opinion on the

                                        -   -7

-------------------- BEGINNING OF PAGE #8 -------------------

financial statements. AU Section 508.42.  Moreover, Tradux's
financial statements were not prepared in accordance with GAAP. 
Regardless, Engel signed unqualified audit reports as to Tradux's
December 31, 1989 and December 31, 1990 financial statements. 
Accordingly, Engel issued improper audit reports.

     Failure to Exercise Due Professional Care

     28.  An auditor must exercise due professional care in
performing an audit and preparing the audit report.  AU Section
230.01.
As described above, Engel failed to exercise due professional
care in the performance of his audits of Tradux's December 31,
1989 and December 31, 1990 financial statements by: 1) opining
that these financial statements were prepared in conformity with
GAAP, and audited in accordance with GAAS, when, in fact, they
were not; 2) inadequately planning the audits;  3) failing to
obtain sufficient competent evidential matter; and 4) improperly
issuing unqualified audit reports.

     29.  Due care also imposes a responsibility upon the auditor
to observe the standards of field work and reporting prescribed
by GAAS.  AU Section230.02.  In addition, an auditor should
exercise due care in planning, performing and evaluating the
results of audit procedures, and maintain a level of professional
skepticism sufficient to reasonably assure that material errors
and irregularities will be detected.  AU Section316.08.  During
the course of his audits of Tradux's December 31, 1989 and
December 31, 1990 financial statements, Engel failed to exercise
due care and to maintain a healthy degree of skepticism by
ignoring facts and GAAP accounting pronouncements which
contradicted Tradux's accounting for certain transactions.  For
example, Engel ignored the family relationships, the sharing of
office space and expenses and other "red flags" which indicated
that Tradux and Advisors may have been under common control. 
Similarly, with respect to the recording of the computer software
programs as assets, Engel knew that the computer software
programs were in a developmental stage, yet disregarded this fact
in evaluating the manner in which the transaction was recorded. 
In addition, Engel failed to recognize that Tradux improperly
recorded revenue on the agreement with Coral as of December 31,
1989, notwithstanding Coral's right to cancel the licensing
agreement and the fact that the shares which Coral issued to
Tradux were to be held in escrow pending Tradux's satisfaction of
significant future obligations. 

     30.  Accordingly, pursuant to Rule 2(e)(1)(ii) of the
Commission's Rules of Practice, the Commission has determined
that Engel engaged in improper professional conduct.



                               III.

     In view of the foregoing, the Commission deems it
appropriate and in the public interest to impose the sanctions
specified in Effren's, Fink's, and Engel's Offers of Settlement.


Accordingly, IT IS ORDERED that:



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-------------------- BEGINNING OF PAGE #9 -------------------

     1.   Effective immediately, Effren cease and desist from
committing or causing any violations and any future violations of
Section 17(a) of the Securities Act and Section 10(b) of the
Exchange Act and Rule 10b-5 thereunder, and from causing any
violation or future violation of Sections 13(a) and 15(d) of the
Exchange Act and Rules 12b-20, 13a-1, 13a-13, 15d-1, 15d-11, and
15d-13 thereunder.

     2.   Effective immediately, Fink be permanently denied the
privilege of appearing or practicing before the Commission as an
accountant.

     3.   Effective immediately, Fink cease and desist from
committing or causing any violations and any future violations of
Section 17(a) of the Securities Act and Section 10(b) of the
Exchange Act and Rule 10b-5 thereunder. 

     4.   Effective immediately, Engel be denied the privilege of
appearing or practicing as an accountant before the Commission.

     5.   Eighteen months after the date of this Opinion and
Order, Engel may apply to the Commission and request that he be
permitted to resume appearing or practicing before the Commission
as:

          a.   a preparer or reviewer of financial statements
          required to be filed with the Commission or a person
          responsible for the preparation or review of financial
          statements required to be filed with the Commission
          provided that, in Engel's practice before the
          Commission, his work will be reviewed by the
          independent audit committee of the company or in some
          other manner acceptable to the staff of the Commission;

          b.   an independent public accountant upon submission
          of an application to the Office of the Chief Accountant
          of the Commission containing a showing satisfactory to
          the Commission that:

               i)   Engel, or any firm with which he is or
               becomes associated in any capacity, is and will
               remain a member of the SEC Practice Section of the
               American Institute of Certified Public Accountants
               Division for CPA Firms ("SEC Practice Section");

               ii)  Engel, or any firm with which he is or
               becomes associated, has received an unqualified
               report relating to his or its most recent peer
               review conducted in accordance with the guidelines
               adopted by the SEC Practice Section; and

               iii) Engel will comply with all applicable SEC
               Practice Section requirements, including all
               requirements for periodic peer reviews, concurring
               partner reviews, and continuing professional
               education, as long as he appears or practices
               before the Commission as an independent
               accountant.

     6.   The Commission's review of any request or application
by Engel to resume appearing or practicing before the Commission
may include consideration of, in addition to the matters referred

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-------------------- BEGINNING OF PAGE #10 -------------------

to above, any other matters relating to Engel's character,
integrity, professional conduct, or qualifications to appear or
practice before the Commission.


     By the Commission.




                                   Jonathan G. Katz
                                   Secretary



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-------------------- BEGINNING OF PAGE #11 -------------------

                           SERVICE LIST

     Rule 23 of the Commission's Rules of Practice provides that
all amendments to moving papers, all answers, all motions or
applications made in the course of a proceeding (unless made
orally during a hearing), all proposed findings and conclusions,
all petitions for review of any initial decision, and all briefs,
shall be filed with the Commission and shall be served upon all
other parties to the proceeding, including the interested
Division of the Commission.

     The Opinion and Order Pursuant To Rule 2(e) of the
Commission's Rules of Practice and Cease and Desist Order in the
above-captioned matter has been sent to the following parties and
other persons entitled to notice:

     Jonathan G. Katz, Secretary
     Securities and Exchange Commission
     Mail Stop 6-9
     450 Fifth Street, N.W.
     Washington, D.C.  20549

     The Honorable Lillian A. McEwen
     Administrative Law Judge
     Securities and Exchange Commission
     Mail Stop 11-6
     450 Fifth Street, N.W.
     Washington, D.C.  20549

     Securities and Exchange Commission
     Northeast Regional Office
     7 World Trade Center
     13th Floor
     New York, New York  10048
          attn:  Martin A. Kuperberg, Senior Associate

     Andrew S. Fink
     58 Bernard Circle
     Centerville,                                                
     Massachusetts  02632                              
          Pro Se    

     
     William Nortman, Esq.
     Nortman & Bloom
     1101 Brickell Avenue, Suite 1400
     Miami, Florida 33131
          Attorney for Lee L. Engel
     
     

     
     
     Robert L. Seaman, Esq.                   
     515 Madison Avenue, Suite 3200           
     New York, New York 10022                
          Attorney for Ronald Effren                             
               
     Ronald L. Effren                        
     Richmond C 421 
     Deerfield Beach, Florida 33442

     Lee L. Engel
     2761 Ocean Club Blvd.
     Hollywood, Florida 33019