UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

   SECURITIES EXCHANGE ACT OF 1934
   Release No. 42182 / November 29, 1999

   ADMINISTRATIVE PROCEEDING
   File No. 3-9654

   ____________________________________
   In the Matter of                     ORDER MAKING
                                        FINDINGS AND
   EUGENE K. LAFF                       IMPOSING SANCTIONS
   Respondent
   ____________________________________

                                     I.

                       ORDER INSTITUTING PROCEEDINGS

   On July 23, 1998, the Securities and Exchange Commission deemed it
   appropriate and in the public interest to institute public
   administrative proceedings against the Respondent, Eugene K. Laff
   ("Laff"), pursuant to Section 15(b) and 19(h) of the Securities
   Exchange Act of 1934 ("Exchange Act").

                                    II.

                                 FINDINGS

   Laff has submitted an Offer of Settlement ("Offer") to the Commission,
   which the Commission has determined to accept. Solely for the purpose
   of this proceedings and any other proceeding brought by, or on behalf
   of the Commission, or to which the Commission is a party, and without
   admitting or denying the findings contained herein except as to
   jurisdiction and the entry of the injunction, which he admits, Laff
   has consented to the issuance of this Order Making Findings and
   Imposing Sanctions.

   On the basis of the Order Instituting Proceedings and Laff's Offer of
   Settlement, the Commission finds that

   A. At all relevant times, Laff was the Chairman of the Board of
   Directors, Chief Executive Officer, and a controlling shareholder of
   Haas Securities Corporation, which was a member of the New York Stock
   Exchange, a broker-dealer registered with the Commission pursuant to
   Section 15(b) of the Exchange Act (15 U.S.C. §78o(b)), and which,