UNITED STATES OF AMERICA
                          FEDERAL TRADE COMMISSION

                              In the Matter of
              LIBERTY FINANCIAL COMPANIES, INC. a corporation.

                             DOCKET NO. _______

                                 COMPLAINT

   The Federal Trade Commission, having reason to believe that Liberty
   Financial Companies, Inc., a corporation ("respondent"), has violated
   the provisions of the Federal Trade Commission Act, and it appearing
   to the Commission that this proceeding is in the public interest,
   alleges:

   1. Respondent Liberty Financial Companies, Inc., is a Massachusetts
   corporation with its principal office or place of business at 600
   Atlantic Avenue, Boston, Massachusetts 02210.

   2. Respondent has operated a World Wide Web ("Web") site located at
   http://www.younginvestor.com  (the "Website").

   3. The acts and practices of respondent alleged in this complaint have
   been in or affecting commerce, as "commerce" is defined in Section 4
   of the Federal Trade Commission Act.

   4. Respondent has disseminated or caused to be disseminated on its
   Website certain Web pages directed at children known as The Young
   Investor Measure Up Survey area. (Exhibit A). At this area, respondent
   conducts a survey that collects from participants numerous items of
   information such as the individual's: weekly amount of allowance;
   types of financial gifts received such as stocks, bonds and mutual
   funds, and from whom; spending habits; part time work history; plans
   for college; and family finances including ownership of any mutual
   funds or investments in the Stein Roe Young Investor Fund offered by
   respondent. The survey states that "(a)ll of your answers will be
   totally anonymous." The survey ends with a section entitled "Entry
   Form" that asks participants what prize they would prefer if they win
   the "quarterly drawing," and asks if they "would like to be added to
   the Young Investor e-mail newsletter." The survey collects personal
   identifying information, including name, age, and gender, and
   participants in the survey are also told to provide e-mail address and
   street address in order to receive the newsletter and for
   identification purposes if they win the drawing.

   5. Through the means described in Paragraph 4, respondent has
   represented, expressly or by implication, that it maintains the

                                Analysis of
                Proposed Consent Order to Aid Public Comment
     _________________________________________________________________

   The Federal Trade Commission has accepted, subject to final approval,
   an agreement containing a consent order from Liberty Financial
   Companies, Inc. ("Liberty Financial"), the operator of a website on
   the World Wide Web located at http://www.younginvestor.com
   ("website").

   The proposed consent order has been placed on the public record for
   sixty (60) days for reception of comments by interested persons.
   Comments received during this period will become part of the public
   record. After sixty (60) days, the Commission will again review the
   agreement and the comments received and will decide whether it should
   withdraw from the agreement or make final the agreement's proposed
   order.

   The Liberty Financial website features several different areas
   targeted to children and teens. One such area is the Measure Up Survey
   area. Participants in this area survey fill out a survey seeking
   financial information, including the individual's: weekly amount of
   allowance; types of financial gifts received such as stocks, bonds and
   mutual funds, and from whom; spending habits; part time work history;
   plans for college; and family finances. Later, the survey elicits the
   individual's name, address, age and email address.

   The Commission's complaint alleges that Liberty Financial made three
   misrepresentations in connection with its collection of this
   information on its website. First, the complaint alleges that Liberty
   Financial represented that the information collected would be "totally
   anonymous." In fact, according to the complaint, all of the
   information collected in the survey area -- the questionnaire
   responses and the participants' personal information -- are maintained
   in one database in identifiable form. Thus, the financial information
   participants provide can be linked to them personally.

   The complaint also alleges that Liberty Financial falsely represented
   that participants in the Measure Up Survey who submit the requested
   personal identifying information will receive the company's Young
   Investor e-mail newsletter. In fact, according to the complaint,
   Liberty Financial did not provide a newsletter to any of the
   participants in the Survey.

   Finally, the complaint alleges that Liberty Financial falsely
   represented that every three months, a participant in the Measure Up
   Survey who submits the requested personal information is selected to
   win his or her choice of certain specified prizes. In fact, according

                          UNITED STATES OF AMERICA
                          FEDERAL TRADE COMMISSION

                              In the Matter of
              LIBERTY FINANCIAL COMPANIES, INC. a corporation.

                             FILE NO. 982 3522
                     AGREEMENT CONTAINING CONSENT ORDER

   The Federal Trade Commission has conducted an investigation of certain
   acts and practices of Liberty Financial Companies, Inc., a corporation
   ("proposed respondent"). Proposed respondent, having been represented
   by counsel, is willing to enter into an agreement containing a consent
   order resolving the allegations contained in the attached draft
   complaint. Therefore,

   IT IS HEREBY AGREED by and between Liberty Financial Companies, Inc.,
   by its duly authorized officer, and counsel for the Federal Trade
   Commission that:

          1. Proposed respondent Liberty Financial Companies, Inc. is a
          Massachusetts corporation with its principal office or place of
          business at 600 Atlantic Avenue, Boston, Massachusetts 02210.


          2. Proposed respondent admits all the jurisdictional facts set
          forth in the draft complaint.


          3. Proposed respondent waives:


                (a) Any further procedural steps;



                (b) The requirement that the Commission's decision
                contain a statement of findings of fact and conclusions
                of law; and


                (c) All rights to seek judicial review or otherwise to
                challenge or contest the validity of the order entered
                pursuant to this agreement.



          4. This agreement shall not become part of the public record of