Case Summary

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ORDER -

On June 8, 2006, Ader and Bradbard were dismissed as Respondents in this matter. The substantive allegations regarding Ader's conduct as alleged in paragraphs 23-25 and 42 of the Complaint were not dismissed.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

ORDER -

On June 8, 2006, Ader and Bradbard were dismissed as Respondents in this matter. The substantive allegations regarding Ader's conduct as alleged in paragraphs 23-25 and 42 of the Complaint were not dismissed.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On December 17, 2004 DeValle filed an Answer to the Complaint in which he denied the material allegations.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

ORDER -

On June 19, 2006, Dym was dismissed as a Cause Respondent.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On October 23, 2006, Meddoff was ordered to pay a $1,000 fine and to not act in any capacity requiring NFA membership or associate membership for 30 days. In addition, Meddoff was ordered, for 6 months (exclusive of any period during which he is not an NFA Member or Associate of an NFA Member), to not be associated with an NFA Member unless Meddoff's sponsor agrees in writing to tape record all conversations that occur between Meddoff and both existing and potential customers; retain each tape for two years from the date the tape is created; and make the tapes available to NFA upon request.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC, and a number of the firm's APs, including Temple, with, among other things, making sales solicitations that exaggerated profit potential and downplayed risk.

ANSWER -

On February 2, 2005, Temple filed an Answer to the Complaint in which he denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Temple was ordered to pay a $12,500 fine and ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Temple was ordered to cause any and all APs sponsored by any Member of which he is a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Temple was further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Temple is an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On June 20, 2006, Executive's NFA membership was terminated and Executive was ordered to never again apply for NFA membership. Kennedy was ordered to terminate his Associate NFA membership and his pending principal status with an NFA Member within thirty days from the date of issuance of the Decision. Kennedy was also ordered to never apply for NFA membership, associate membership or principal status with any NFA Member and not act in a supervisory capacity for any NFA Member at any time in the future.

Cambell was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until he has paid a $12,500 fine in full. DeValle was suspended from NFA associate membership for a continuous period of thirty days and ordered to pay a $7,500 fine. Jimenez was ordered to pay a $15,000 fine. Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for six months. In addition, notwithstanding any other provisions of the Decision, Larkins was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member unless and until she has paid a $2,500 fine in full. Singh was ordered to pay a $10,000 fine. Vallee was ordered to pay a $7,500 fine. Temple was ordered to pay a $12,500 fine.

In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were ordered to cause any and all APs sponsored by any Member of which they are a principal during the six-month period to tape record any and all conversations with customers or prospective customers. Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple were further ordered to retain any and all recordings required to be created for one year from the date of their creation and promptly produce such recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Campbell, DeValle, Jimenez, Larkins, Singh, Vallee and Temple are an NFA Member or a principal or an Associate of an NFA Member count toward the fulfillment of these obligations.

COMPLAINT -

On November 12, 2004, NFA issued a Complaint charging ECC with using deceptive and misleading promotional material; failing to properly classify non-current assets; failing to maintain required minimum net capital; and failing to meet anti-money laundering requirements. ECC and Kennedy were charged with failing to diligently supervise employees and agents in the conduct of their commodity futures activities. ECC and Kennedy were charged with failure to uphold high standards of commercial honor and just and equitable principles of trade and Dym was alleged to be the cause of this violation. ECC and some of its APs were charged with making deceptive and misleading sales solicitations and using a high-pressure approach.

ANSWER -

On February 2, 2005, Executive, Kennedy, Dym, Bradbard, Campbell, Jimenez, Larkins, Meddoff, Singh, Vallee, Temple and Zedeck filed an Answer to the Complaint in which they denied the material allegations contained therein and requested a hearing before NFA's Hearing Committee.

DECISION -

On January 31, 2006, Zedeck was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for three years. In addition, Zedeck was ordered to tape record any and all conversations that he has with customers or prospective customers for six months. He must promptly produce to NFA any and all recordings required to be created in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Zedeck is an NFA Member or an Associate of an NFA Member will be counted toward fulfillment of this obligation. This Decision is in conjunction with NFA Case No. 05-BCC-007.