Case Summary

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 1, 2007, Agdaian filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION -

On May 16, 2008, Agdaian was suspended from NFA associate membership and from acting as a principal of an NFA Member for three months. During the three-month suspension, Agdaian may not act in any capacity requiring registration, nor act as a principal of an NFA Member. Agdaian was also ordered to pay a $20,000 fine.

Agdaian must tape record, for one year, all conversations between himself and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. The one-year taping requirement begins on the date Agdaian's three-month suspension expires and continues thereafter for one year. In calculating the one-year period, only when Agdaian is registered and actively soliciting customers will be counted.

Should Agdaian become a principal of an NFA Member, he must cause all APs of that firm - and any other firm of which he is a principal - to tape record, for one year, all conversations that occur between them and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. This applies to each and every firm of which Agdaian becomes a principal and begins on the date he becomes a principal of each firm, respectively. Only periods of time when Agdaian is a principal of that particular firm and that firm is actively soliciting customers will be counted. In any and all events, the taping requirements expire on December 31, 2012.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 9, 2007, ANTC, Varden, Zummo and Roy filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On November 29, 2007, ANTC was permanently barred from NFA membership and from acting as a principal of an NFA Member. Varden was ordered to pay a $40,000 fine and Zummo and Roy were ordered to each pay a $20,000 fine. Varden and Zummo were each barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Varden or Zummo becomes a principal of an NFA Member, then during the time he is a principal of such Member, he will cause such Member to be subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9. After a Member, of which Varden and/or Zummo is a principal, has been subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9 for at least 18 months, then Varden and/or Zummo will be permitted to make an application with NFA's Waiver Committee for a waiver of the enhanced supervisory requirements with respect to such Member.

Roy was barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Roy becomes a principal of a Member other than Peregrine Financial Group, Inc. or should he cease being a principal of PFG and, subsequently again becomes a principal of PFG, he will be counted as having been a principal and AP of a Disciplined Firm, viz., ANTC, which had also been subject to NFA's Enhanced Supervisory Requirements.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 1, 2007, Flowers filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION -

On December 10, 2007, Flowers was permanently barred from NFA membership and associate membership and from acting as a principal of an NFA Member.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On January 31, 2007, Mata filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION -

On May 16, 2008, Mata was suspended from NFA associate membership and from acting as a principal of an NFA Member for thirty days. During the thirty-day suspension, Mata may not act in any capacity requiring registration, nor act as a principal of an NFA Member. Mata was also ordered to pay a $5,000 fine.

Mata must tape record, for one year, all conversations between himself and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. The one-year taping requirement begins on the date Mata's thirty-day suspension expires and continues thereafter for one year. In calculating the one-year period, only when Mata is registered and actively soliciting customers will be counted.

Should Mata become a principal of an NFA Member, he must cause all APs of that firm - and any other firm of which he is a principal - to tape record, for one year, all conversations that occur between them and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. This applies to each and every firm of which Mata becomes a principal and begins on the date he becomes a principal of each firm, respectively. Only periods of time when Mata is a principal of that particular firm and that firm is actively soliciting customers will be counted. In any and all events, the taping requirements expire on December 31, 2012.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 9, 2007, ANTC, Varden, Zummo and Roy filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On November 29, 2007, ANTC was permanently barred from NFA membership and from acting as a principal of an NFA Member. Varden was ordered to pay a $40,000 fine and Zummo and Roy were ordered to each pay a $20,000 fine. Varden and Zummo were each barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Varden or Zummo becomes a principal of an NFA Member, then during the time he is a principal of such Member, he will cause such Member to be subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9. After a Member, of which Varden and/or Zummo is a principal, has been subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9 for at least 18 months, then Varden and/or Zummo will be permitted to make an application with NFA's Waiver Committee for a waiver of the enhanced supervisory requirements with respect to such Member.

Roy was barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Roy becomes a principal of a Member other than Peregrine Financial Group, Inc. or should he cease being a principal of PFG and, subsequently again becomes a principal of PFG, he will be counted as having been a principal and AP of a Disciplined Firm, viz., ANTC, which had also been subject to NFA's Enhanced Supervisory Requirements.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 7, 2007, Snow filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION -

On May 16, 2008, Snow was suspended from NFA associate membership and from acting as a principal of an NFA Member for three months. During the three-month suspension, Snow may not act in any capacity requiring registration, nor act as a principal of an NFA Member. Snow was also ordered to pay a $20,000 fine.

Snow must tape record, for one year, all conversations between himself and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. The one-year taping requirement begins on the date Snow's three-month suspension expires and continues thereafter for one year. In calculating the one-year period, only when Snow is registered and actively soliciting customers will be counted.

Should Snow become a principal of an NFA Member, he must cause all APs of that firm - and any other firm of which he is a principal - to tape record, for one year, all conversations that occur between them and existing or potential customers; retain the tapes for one year; and make the tapes available to NFA. This applies to each and every firm of which Snow becomes a principal and begins on the date he becomes a principal of each firm, respectively. Only periods of time when Snow is a principal of that particular firm and that firm is actively soliciting customers will be counted. In any and all events, the taping requirements expire on December 31, 2012.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 7, 2007, Vardanian filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION -

On November 20, 2007, Vardanian was permanently barred from NFA membership and associate membership and from acting as a principal of an NFA Member.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 9, 2007, ANTC, Varden, Zummo and Roy filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On November 29, 2007, ANTC was permanently barred from NFA membership and from acting as a principal of an NFA Member. Varden was ordered to pay a $40,000 fine and Zummo and Roy were ordered to each pay a $20,000 fine. Varden and Zummo were each barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Varden or Zummo becomes a principal of an NFA Member, then during the time he is a principal of such Member, he will cause such Member to be subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9. After a Member, of which Varden and/or Zummo is a principal, has been subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9 for at least 18 months, then Varden and/or Zummo will be permitted to make an application with NFA's Waiver Committee for a waiver of the enhanced supervisory requirements with respect to such Member.

Roy was barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Roy becomes a principal of a Member other than Peregrine Financial Group, Inc. or should he cease being a principal of PFG and, subsequently again becomes a principal of PFG, he will be counted as having been a principal and AP of a Disciplined Firm, viz., ANTC, which had also been subject to NFA's Enhanced Supervisory Requirements.

COMPLAINT -

On November 16, 2006, NFA issued a Complaint charging ANTC, Vardanian, Flowers, Snow, Agdaian and Mata with making deceptive, misleading and high-pressured sales solicitations. The Complaint also charged ANTC, Varden, Zummo and Roy with failing to diligently supervise employees and agents in the conduct of their commodity futures activities.

ANSWER -

On February 9, 2007, ANTC, Varden, Zummo and Roy filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On November 29, 2007, ANTC was permanently barred from NFA membership and from acting as a principal of an NFA Member. Varden was ordered to pay a $40,000 fine and Zummo and Roy were ordered to each pay a $20,000 fine. Varden and Zummo were each barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Varden or Zummo becomes a principal of an NFA Member, then during the time he is a principal of such Member, he will cause such Member to be subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9. After a Member, of which Varden and/or Zummo is a principal, has been subject to the enhanced supervisory requirements of NFA Compliance Rule 2-9 for at least 18 months, then Varden and/or Zummo will be permitted to make an application with NFA's Waiver Committee for a waiver of the enhanced supervisory requirements with respect to such Member.

Roy was barred from acting as a principal of an NFA Member until May 11, 2009. If, after May 11, 2009, Roy becomes a principal of a Member other than Peregrine Financial Group, Inc. or should he cease being a principal of PFG and, subsequently again becomes a principal of PFG, he will be counted as having been a principal and AP of a Disciplined Firm, viz., ANTC, which had also been subject to NFA's Enhanced Supervisory Requirements.