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Case Summary

MOHR & MOORE LLC NFA 11BCC00019 NFA ID: 0412404

Respondent/Effective Date Summary
 NFA IDRespondentEffective Date
 0412404MOHR & MOORE LLC01/05/2012
 0274245MOORE, WILLIAM ELMER01/05/2012
Rule Summary
 NFA IDRespondentRule Type
 0412404MOHR & MOORE LLC• C.R.2-39 - SOLICITING, INTRODUCING, OR MANAGING OFF-EXCHANGE RETAIL FOREX TRANSACTIONS OR ACCOUNTS
  • C.R.2-41(b) - FOREX TRADING ADVISORS-FILE DISCLOSURE DOCUMENT WITH NFA AND PROVIDE TO CLIENTS
  • C.R.2-36(c) - FOREX DEALER MEMBERS OBSERVE HIGH STDS OF COMMERCIAL HONOR
 0274245MOORE, WILLIAM ELMER• C.R.2-41(b) - FOREX TRADING ADVISORS-FILE DISCLOSURE DOCUMENT WITH NFA AND PROVIDE TO CLIENTS
  • C.R.2-10 - RECORDKEEPING FCMS/IBS
  • C.R.2-36(c) - FOREX DEALER MEMBERS OBSERVE HIGH STDS OF COMMERCIAL HONOR
  • C.R.2-39 - SOLICITING, INTRODUCING, OR MANAGING OFF-EXCHANGE RETAIL FOREX TRANSACTIONS OR ACCOUNTS
Committee Summary
 NFA IDRespondentCommittee
 0412404MOHR & MOORE LLC• BUSINESS CONDUCT COMMITTEE
  • HEARING COMMITTEE
 0274245MOORE, WILLIAM ELMER• BUSINESS CONDUCT COMMITTEE
  • HEARING COMMITTEE
Action Summary
 NFA IDRespondentAction Types
 0412404MOHR & MOORE LLC• GENERAL CONDUCT
  • SALES PRACTICE
 0274245MOORE, WILLIAM ELMER• OFFICE RECORDKEEPING
  • GENERAL CONDUCT
  • SALES PRACTICE
Penalty/Event Summary
 NFA IDRespondentPenalty/EventEvent Date
 0412404MOHR & MOORE LLC• PERMANENT BAR FROM NFA ASSOCIATE MEMBERSHIP12/21/2011
  • WITHDRAW FROM MEMBERSHIP12/21/2011
  • PERMANENT BAR FROM NFA MEMBERSHIP12/21/2011
  • PERMANENT BAR FROM PRINCIPAL STATUS12/21/2011
 0274245MOORE, WILLIAM ELMER• FINE (CONTINGENT) $4000012/21/2011
  • TEMPORARY BAR FROM NFA ASSOCIATE MEMBERSHIP 5 YRS12/21/2011
  • TEMPORARY BAR FROM PRINCIPAL STATUS 5 YRS12/21/2011
  • OTHER--SEE NARRATIVE12/21/2011
  • WITHDRAW FROM NFA ASSOCIATE MEMBERSHIP12/21/2011
Narrative Summary
Narrative for 0412404 - MOHR & MOORE LLC
COMPLAINT:

On August 31, 2011, NFA issued a Complaint charging Moore and M&M with failing to provide an approved disclosure document to customers; failing to uphold high standards of commercial honor; and failing to disclose material information to customers. The Complaint also charged M&M with failing to maintain required records.

ANSWER:

On October 4, 2011, M&M and Moore filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On December 21, 2011, pursuant to a settlement offer submitted by M&M and Moore, M&M and Moore were ordered to withdraw from NFA membership and associate membership, respectively, within 30 days of the date of the Decision. M&M was ordered to never again apply for NFA membership, associate membership and principal status with any NFA Member. Moore was ordered not to apply for NFA associate membership or principal status with any NFA Member for five years from the date of his withdrawal. In the event that he is granted NFA associate membership or approved as a principal of an NFA Member at any time in the future, Moore was ordered to pay a $40,000 fine. Finally, in the event that Moore attains NFA membership or associate membership in the future, he may not act in the capacity of a CTA or manage, direct or exercise discretionary trading authority over any accounts, either pursuant to a power of attorney, a letter of direction, or verbal authorization from a customer.

 
Narrative for 0274245 - MOORE, WILLIAM ELMER
COMPLAINT:

On August 31, 2011, NFA issued a Complaint charging Moore and M&M with failing to provide an approved disclosure document to customers; failing to uphold high standards of commercial honor; and failing to disclose material information to customers. The Complaint also charged M&M with failing to maintain required records.

ANSWER:

On October 4, 2011, M&M and Moore filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On December 21, 2011, pursuant to a settlement offer submitted by M&M and Moore, M&M and Moore were ordered to withdraw from NFA membership and associate membership, respectively, within 30 days of the date of the Decision. M&M was ordered to never again apply for NFA membership, associate membership and principal status with any NFA Member. Moore was ordered not to apply for NFA associate membership or principal status with any NFA Member for five years from the date of his withdrawal. In the event that he is granted NFA associate membership or approved as a principal of an NFA Member at any time in the future, Moore was ordered to pay a $40,000 fine. Finally, in the event that Moore attains NFA membership or associate membership in the future, he may not act in the capacity of a CTA or manage, direct or exercise discretionary trading authority over any accounts, either pursuant to a power of attorney, a letter of direction, or verbal authorization from a customer.

 
Case Documents Summary
 NFA IDRespondentDocument Type
 0412404MOHR & MOORE LLCANSWER
 0412404MOHR & MOORE LLCCOMPLAINT
 0412404MOHR & MOORE LLCDECISION
 0274245MOORE, WILLIAM ELMERANSWER
 0274245MOORE, WILLIAM ELMERCOMPLAINT
 0274245MOORE, WILLIAM ELMERDECISION
 
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