3. Pursuant to the provisions of Section 13(f) of the Exchange Act and Rule 13f-1 thereunder, Cabot Money Management and Lutts were obligated to file a Form 13F disclosing their holdings of "Section 13(f) securities" as of December 31, 1995, within 45 days of December 31, 1995 -- the last day of the calendar year in which they first exercised investment discretion with respect to accounts holding "Section 13(f) securities" having an aggregate fair market value on the last trading day of any month in that calendar year of at least $100 million. That Form 13F should have been filed on or before February 14, 1996.

4. Cabot Money Management and Lutts were obligated to file a second Form 13F within 45 days of March 31, 1996 -- the last day of the following calendar quarter, disclosing their holdings of "Section 13(f) securities" as of the end of that quarter. That Form 13F should have been filed on or before May 15, 1996.

5. Cabot Money Management and Lutts did not file the required Forms 13F with the Commission until June 11, 1996. On that date, Cabot Money Management and Lutts filed two Forms 13F, one reflecting their holding of more than $138 million of "Section 13(f) securities" as of December 31, 1995, the other reflecting their holding of more than $199 million of "Section 13(f) securities" as of March 29, 1996, the last trading day of that quarter.

Cabot Money Management and Lutts shall, within ten days of the date of this Order, each pay a civil penalty in the amount of twelve thousand five hundred dollars ($12,500) to the United States Treasury. Such payment shall be: (A) made by United States postal money order, certified check, bank cashier's check or bank money order; (B) made payable to the Securities and Exchange Commission; (C) hand-delivered to the Comptroller, Securities and Exchange Commission, 450 Fifth Street, N.W. Washington, D.C. 20549; and (D) submitted under cover letter identifying Cabot Money Management and Lutts as Respondents in these proceedings, the file number of these proceedings, and the Commission's case number, a copy of which cover letter and money order shall be sent to Erich T. Schwartz, Assistant Director, Division of Enforcement, Securities and Exchange Commission, 450 Fifth Street, N.W., Stop 5-4, Washington, D.C. 20549.