| STEVEN JOHN BREWER |
NFA 06BCC00008 |
NFA ID: 0246323 |
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| 0300729 | BREWER FUTURES GROUP LLC | 04/02/2007 | | 0246323 | BREWER, STEVEN JOHN | 04/02/2007 |
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| 0300729 | BREWER FUTURES GROUP LLC | • C.R.2-29(b)(5) - REF. TO ACTUAL PAST TRADING PROFITS | | | | • C.R.2-10 - RECORDKEEPING FCMS/IBS | | | | • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM | | | | • C.R.2-29(e) - RECDKEEPING PROMO MATERIALS | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0246323 | BREWER, STEVEN JOHN | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES |
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| 0300729 | BREWER FUTURES GROUP LLC | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE | | 0246323 | BREWER, STEVEN JOHN | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE |
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| 0300729 | BREWER FUTURES GROUP LLC | • GENERAL CONDUCT | | | | • SALES PRACTICE | | | | • OFFICE RECORDKEEPING | | 0246323 | BREWER, STEVEN JOHN | • GENERAL CONDUCT |
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| 0300729 | BREWER FUTURES GROUP LLC | • SUBMIT PROMOTIONAL MATERIAL TO NFA INDF | 03/16/2007 | | | | • FINE (JOINTLY AND SEVERALLY) $45000 | 03/16/2007 | | | | • OTHER--SEE NARRATIVE | 03/16/2007 | | 0246323 | BREWER, STEVEN JOHN | • SUBMIT PROMOTIONAL MATERIAL TO NFA INDF | 03/16/2007 | | | | • FINE (JOINTLY AND SEVERALLY) $45000 | 03/16/2007 | | | | • OTHER--SEE NARRATIVE | 03/16/2007 |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT -
On May 23, 2006, NFA issued a Complaint charging BFG with failure to: file and distribute pool statements; maintain support for performance data in promotional material; review and approve promotional material; maintain required books and records; and implement an adequate anti-money laundering program. In addition, the Complaint charged BFG and Brewer with failure to supervise.
ANSWER -
On July 11, 2006, BFG and Brewer filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION -
On March 16, 2007, BFG and Brewer were ordered to jointly and severally pay a $45,000 fine. It was also ordered that neither BFG nor any other NFA Member of which Brewer is a principal shall at any time in the future: apply for registration as a CPO; operate any commodity pools; use any promotional material unless such material has been specifically approved by NFA prior to first use; and employ any AP who has been sponsored by a Member that is on NFA's list of firms that have been disciplined for sales practice fraud. The number of APs that BFG or any other NFA Member of which Brewer is a principal shall be limited to the number of APs sponsored by BFG as of March 13, 2007. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
COMPLAINT -
On May 23, 2006, NFA issued a Complaint charging BFG with failure to: file and distribute pool statements; maintain support for performance data in promotional material; review and approve promotional material; maintain required books and records; and implement an adequate anti-money laundering program. In addition, the Complaint charged BFG and Brewer with failure to supervise.
ANSWER -
On July 11, 2006, BFG and Brewer filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION -
On March 16, 2007, BFG and Brewer were ordered to jointly and severally pay a $45,000 fine. It was also ordered that neither BFG nor any other NFA Member of which Brewer is a principal shall at any time in the future: apply for registration as a CPO; operate any commodity pools; use any promotional material unless such material has been specifically approved by NFA prior to first use; and employ any AP who has been sponsored by a Member that is on NFA's list of firms that have been disciplined for sales practice fraud. The number of APs that BFG or any other NFA Member of which Brewer is a principal shall be limited to the number of APs sponsored by BFG as of March 13, 2007. | | |
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