Case Summary

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION:

On July 23, 2009, NFA issued a Member Responsibility Action ("MRA") against RCM and an Associate Responsibility Action against Hamilton whereby:

1. RCM and Hamilton are prohibited from soliciting or accepting any customer or pool participants’ funds;

2. RCM and Hamilton are prohibited from placing trades or transactions on behalf of any customers or pools, except for liquidation purposes;

3. RCM and Hamilton are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts) in the name of RCM or any pools operated by RCM, including but not limited to, the Raleigh Fund, L.P. (the “Fund”) without prior approval from NFA; and

4. RCM and Hamilton are required to provide copies of this MRA via overnight courier to the following: (i) all pool participants in any pools that RCM or Hamilton operates or over which they exercise control; (ii) all banks and other financial institutions with which money is on deposit in the name of RCM; and (iii) any pool that RCM or Hamilton operates or over which they exercise control.

This action is effective immediately and is deemed necessary to protect the commodity futures markets, customers, or other NFA Members or Associates because Hamilton has provided information to NFA regarding his ability to honor redemption requests from participants in the Fund that contradicts the information provided by participants in the Fund. Additionally, Hamilton took money from the Fund, which he has characterized as loans, although there are no loan documents and, for almost a year now, he has failed to pay interest on these purported loans. This is contrary to RCM's representation to the Fund's participants that Hamilton was paying interest. Moreover, at least a portion of these purported loans appears to have been used for purposes inconsistent with the Fund's private placement memorandum.

It also appears that RCM and Hamilton have acted in a manner that is contrary to the interests of the Fund and its participants by purchasing property from Hamilton that included the assumption of mortgages on these properties without providing participants with a full disclosure of the transactions, including certain conflicts of interest posed by Hamilton's self-dealing. Additionally, RCM has failed to properly disclose or record investments by the Fund in a venture in which at least one owner is Hamilton's relative, and failed to properly disclose another investment in a venture with these same persons.

The MRA will remain in effect until such time as RCM and Hamilton have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA requirements.

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION:

On July 23, 2009, NFA issued a Member Responsibility Action ("MRA") against RCM and an Associate Responsibility Action against Hamilton whereby:

1. RCM and Hamilton are prohibited from soliciting or accepting any customer or pool participants’ funds;

2. RCM and Hamilton are prohibited from placing trades or transactions on behalf of any customers or pools, except for liquidation purposes;

3. RCM and Hamilton are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts) in the name of RCM or any pools operated by RCM, including but not limited to, the Raleigh Fund, L.P. (the “Fund”) without prior approval from NFA; and

4. RCM and Hamilton are required to provide copies of this MRA via overnight courier to the following: (i) all pool participants in any pools that RCM or Hamilton operates or over which they exercise control; (ii) all banks and other financial institutions with which money is on deposit in the name of RCM; and (iii) any pool that RCM or Hamilton operates or over which they exercise control.

This action is effective immediately and is deemed necessary to protect the commodity futures markets, customers, or other NFA Members or Associates because Hamilton has provided information to NFA regarding his ability to honor redemption requests from participants in the Fund that contradicts the information provided by participants in the Fund. Additionally, Hamilton took money from the Fund, which he has characterized as loans, although there are no loan documents and, for almost a year now, he has failed to pay interest on these purported loans. This is contrary to RCM's representation to the Fund's participants that Hamilton was paying interest. Moreover, at least a portion of these purported loans appears to have been used for purposes inconsistent with the Fund's private placement memorandum.

It also appears that RCM and Hamilton have acted in a manner that is contrary to the interests of the Fund and its participants by purchasing property from Hamilton that included the assumption of mortgages on these properties without providing participants with a full disclosure of the transactions, including certain conflicts of interest posed by Hamilton's self-dealing. Additionally, RCM has failed to properly disclose or record investments by the Fund in a venture in which at least one owner is Hamilton's relative, and failed to properly disclose another investment in a venture with these same persons.

The MRA will remain in effect until such time as RCM and Hamilton have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA requirements.