This matter involves Quattro’s repeated failure to file Forms 13F with the Commission between 2002 and mid-2005. Section 13(f) of the Exchange Act requires institutional investment managers who exercise investment discretion over at least $100 million of certain securities (called “Section 13(f) securities”) to file a Form 13F quarterly with the Commission disclosing the Section 13(f) securities under management. The purpose of this disclosure requirement is to collect and disseminate to the public information about the holdings and investment activities of institutional money managers in order to assist investors, issuers and government regulators. Since 2001, Quattro’s assets under management have exceeded the $100 million threshold in Section 13(f) securities, obligating Quattro to file a Form 13F each quarter beginning in 2002. However, Quattro failed to file any Forms 13F until July 2005, when the Commission’s inspection staff began questioning Quattro about the absence of such filings.

Quattro pay, within 30 days of the entry of this Order, a civil money penalty in the amount of $100,000 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 or mailed to the Office of Financial Management, Securities and Exchange Commission, Operations Center, 6432 General Green Way, Stop 0-3, Alexandria, VA 22312; and (D) submitted under cover letter that identifies Quattro as the Respondent in these proceedings and the file number of these proceedings, a copy of which cover letter and money order or check shall be sent to Bruce Karpati, Assistant Regional Director, Division of Enforcement, Securities and Exchange Commission, New York Regional Office, 3 World Financial Center, New York, NY 10281.