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NOTICE OF MEMBER RESPONSIBILITY ACTION:
On February 12, 2009, NFA issued a Member Responsibility Action ("MRA") against Paul Greenwood ("Greenwood") and Stephen Walsh ("Walsh") whereby:
1. Greenwood and Walsh are suspended from NFA membership until further notice;
2. Greenwood and Walsh and any other person acting on behalf of either of them are prohibited from soliciting or accepting any customer or pool participant funds or placing trades for any pools that they operate or accounts that they own or control or which are held in either of their names except for liquidation of existing positions;
3. Greenwood and Walsh and any other person acting on behalf of either of them are prohibited from disbursing or transferring any funds (other than to margin existing positions) from any accounts (bank, trading, or any other types of accounts) which either of them owns or controls (including customer and pool accounts) or which are held in either of their names, without prior approval from NFA; and
4. Greenwood and Walsh are required to provide copies of this MRA via overnight courier to all pool participants in any pool which Greenwood and/or Walsh operates, exercises control over or which either of them previously exercised control over.
These actions are effective immediately and are deemed necessary to protect the commodity futures markets, pool participants, customers and other NFA Members because Greenwood and Walsh have failed to cooperate with NFA and produce books and records relating to their CPO activities, including books and records of all other transactions and all other activities in which they engage. Moreover, as explained below, they have failed to respond to questions regarding numerous promissory notes totaling hundreds of millions of dollars executed by them individually in favor of an investment vehicle to which an NFA listed commodity pool has loaned approximately $350 million, and failed to make themselves available to respond to questions regarding another listed commodity pool's $194.5 million loan to the same investment vehicle.
The MRA will remain in effect until such time as Greenwood and Walsh have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements. Greenwood and Walsh are required to provide copies of this MRA by overnight courier to all of their customers, the WCM Fund's customers, WGTC's customers and to all banks and other financial institutions with which they have money on deposit.