Case Summary

On September 14, 2005, NFA issued a Member Responsibility Action ("MRA") against Lake Dow and Edwards whereby:

1. Lake Dow and Edwards are suspended from NFA membership and associate membership, respectively, effective immediately.

2. Lake Dow and Edwards are prohibited from soliciting or accepting any customer or pool participant funds or placing trades for any pools that they operate or accounts that they own or control or which are held in either of their names except for liquidation of existing positions;

3. Lake Dow and Edwards are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts) which they own or control (including customer accounts) or which are held in either of their names, without prior approval from NFA; and

4. Lake Dow and Edwards are required to provide copies of this MRA and ARA via overnight courier to all customers having accounts, which either Lake Dow or Edwards control, and to pool participants in any pools which Lake Dow or Edwards operate or over which either of them exercises control, including but not limited to the Aurora Investment Fund L.P. ("the Aurora Fund" or "the pool").

These actions are effective immediately and are deemed necessary to protect the commodity futures markets, pool participants, customers, and other NFA Members because Lake Dow and Edwards have: a) prepared and distributed statements to participants in the Aurora Fund that showed profitable trading which - by Edwards' own admission - were not derived from underlying trading and bank records but, apparently, were mere estimates of the pool's performance for which Edwards had no underlying documentation or support; b) provided misleading information to NFA concerning the ownership of Lake Dow - i.e., at first, Edwards represented that he was the sole owner of Lake Dow but, later, he changed his story and said that there were other investors in Lake Dow; c) failed to identify all investors in Lake Dow or the amounts they invested or the amounts invested by all of the participants in the Aurora Fund; d) failed to prepare and maintain required financial records for Lake Dow and the Aurora Fund; e) failed to produce to NFA all books and records requested by NFA in connection with an examination of Lake Dow; f) failed to file audited financial statements for fiscal years 2003 and 2004 for the Aurora Fund; and g) used, and continue to use, an outdated disclosure document from 2002 for the pool, which fails to disclose material administrative and civil actions against Edwards (viz., a 2002 NFA disciplinary action in which Edwards was charged with providing false information to NFA in the course of an audit and using a misleading sales script to train APs and a 2003 CFTC injunctive action in which he was charged with sales fraud), and contains hypothetical performance results which are not permitted where, as here, the pool has three months of actual performance. Thus, Lake Dow and Edwards have failed to demonstrate that they are in compliance with NFA Requirements.

The MRA and ARA will remain in effect until such time as Lake Dow and Edwards demonstrate to the satisfaction of NFA that they are in complete compliance with all NFA Requirements. NFA Members receiving notice of the MRA and ARA by service or otherwise who carry accounts in the name of, or controlled by, Lake Dow and Edwards, or either of them, are prohibited from disbursing or transferring funds to Lake Dow or Edwards or any entity controlled by them for any reason without prior approval of NFA.

On September 14, 2005, NFA issued a Member Responsibility Action ("MRA") against Lake Dow and Edwards whereby:

1. Lake Dow and Edwards are suspended from NFA membership and associate membership, respectively, effective immediately.

2. Lake Dow and Edwards are prohibited from soliciting or accepting any customer or pool participant funds or placing trades for any pools that they operate or accounts that they own or control or which are held in either of their names except for liquidation of existing positions;

3. Lake Dow and Edwards are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts) which they own or control (including customer accounts) or which are held in either of their names, without prior approval from NFA; and

4. Lake Dow and Edwards are required to provide copies of this MRA and ARA via overnight courier to all customers having accounts, which either Lake Dow or Edwards control, and to pool participants in any pools which Lake Dow or Edwards operate or over which either of them exercises control, including but not limited to the Aurora Investment Fund L.P. ("the Aurora Fund" or "the pool").

These actions are effective immediately and are deemed necessary to protect the commodity futures markets, pool participants, customers, and other NFA Members because Lake Dow and Edwards have: a) prepared and distributed statements to participants in the Aurora Fund that showed profitable trading which - by Edwards' own admission - were not derived from underlying trading and bank records but, apparently, were mere estimates of the pool's performance for which Edwards had no underlying documentation or support; b) provided misleading information to NFA concerning the ownership of Lake Dow - i.e., at first, Edwards represented that he was the sole owner of Lake Dow but, later, he changed his story and said that there were other investors in Lake Dow; c) failed to identify all investors in Lake Dow or the amounts they invested or the amounts invested by all of the participants in the Aurora Fund; d) failed to prepare and maintain required financial records for Lake Dow and the Aurora Fund; e) failed to produce to NFA all books and records requested by NFA in connection with an examination of Lake Dow; f) failed to file audited financial statements for fiscal years 2003 and 2004 for the Aurora Fund; and g) used, and continue to use, an outdated disclosure document from 2002 for the pool, which fails to disclose material administrative and civil actions against Edwards (viz., a 2002 NFA disciplinary action in which Edwards was charged with providing false information to NFA in the course of an audit and using a misleading sales script to train APs and a 2003 CFTC injunctive action in which he was charged with sales fraud), and contains hypothetical performance results which are not permitted where, as here, the pool has three months of actual performance. Thus, Lake Dow and Edwards have failed to demonstrate that they are in compliance with NFA Requirements.

The MRA and ARA will remain in effect until such time as Lake Dow and Edwards demonstrate to the satisfaction of NFA that they are in complete compliance with all NFA Requirements. NFA Members receiving notice of the MRA and ARA by service or otherwise who carry accounts in the name of, or controlled by, Lake Dow and Edwards, or either of them, are prohibited from disbursing or transferring funds to Lake Dow or Edwards or any entity controlled by them for any reason without prior approval of NFA.