UNITED STATES OF AMERICA
Before the
COMMODITY FUTURES TRADING COMMISSION

ROSE SCOTT
                                v.
CFTC Docket No. 99-R042
DANIEL GILBERT GOULD,
INTEGRAED BROKERATE SERVICES,
IND., and LFG, LLC
ORDER OF SUMMARY
AFFIRMANCE

Our review of the record and the appellate submissions establishes that the findings and conclusions of the presiding officer are supported by the weight of the evidence; we therefore adopt them. We further conclude that the presiding officer committed no error material to the outcome of this proceeding and that the parties have not raised important questions of law or policy meriting extended discussion.1  Accordingly, we affirm the result reached in the Initial Decision.

IT IS SO ORDERED.2

By the Commission (Chairman RAINER and Commissioners HOLUM, SPEARS, NEWSOME and ERICKSON).

Jean A. Webb
Secretary of the Commission
Commodity Futures Trading Commission

Dated: September 29, 2000


  1 After the Judgment Office issued this decision, we announced a new standard material to the issues raised in complainant's appeal.  Gray v. LFG, LLC, CFTC Docket No. 99-R108 (CFTC Sept. 12, 2000).  The result of the Judgment Officer's analysis is consistent with the result reached when the Gray standard is applied.

2 Under Sections 6(c) and 14(e) of the Commodity Exchange Act, 7 U.S.C. §§ 9 and 18(e)(1994), a party may appeal a reparation order of the Commission to the United States Court of Appeals for only the circuit in which a hearing was held; if no hearing was held, the appeal may be filed in any circuit in which the appellee is located. The statute also states that such an appeal must be filed within 15 days after notice of the order and that any appeal is not effective unless, within 30 days of the date of the Commission order, the appealing party files with the court a bond equal to double the amount of any reparation award.