Case Summary

Notice of Member Responsibility Action and Associate Responsibility Action:

On August 27, 2010, NFA issued a Member Responsibility Action ("MRA") against Spirit Investments, Inc. and an Associate Responsibility Action ("ARA") against Scott A. Bottolfson whereby:

1. Bottolfson and Spirit are prohibited from soliciting or accepting any funds from customers or investors, soliciting investments for any commodity pools or other investment vehicles, or placing any trades on behalf of customers, commodity pools, or investors except liquidation or risk reducing trades in Kingship Commodities Group LP ("Kingship Fund"), Increase Investments, Inc., or any other fund, accounts or investment vehicles over which Bottolfson exercises control;

2. Bottolfson and Spirit are prohibited from disbursing or transferring any funds of customers, investors, commodity pools over which they exercise control, or participants in any such commodity pools, without prior approval from NFA; and

3. Bottolfson and Spirit are required to provide copies of this MRA/ARA via overnight courier to all: a) customers; b) participants in the Kingship Fund and Increase Investments, Inc. and all investors in any other funds or investment vehicles over which Bottolfson and/or Spirit exercises control; and c) to all banks, brokerage firms, and other financial institutions in which money is on deposit in the name of Spirit, Kingship Fund, Increase Investments, Inc., or any other entity over which Bottolfson exercises control.

This action is effective immediately and is deemed necessary to protect customers of Spirit, Kingship Fund, Increase Investments, Inc., and Bottolfson, as well as investors in commodity pools and other investment vehicles controlled by Spirit and/or Bottolfson, based on the following facts and circumstances: NFA has received information that Bottolfson and Increase Investments, Inc. obtained substantial sums of money from investors (perhaps as much as $6 million from as many as thirty investors) to whom Bottolfson and Increase Investments, Inc. issued promissory notes and represented that investors' money would be used to trade futures. However, Bottolfson had previously represented to NFA auditors that Increase Investments, Inc. only traded physicals and real estate. NFA has now learned that investors who gave money to Bottolfson and/or Increase Investments, Inc. have been advised that most, if not all, of their investments have been lost. In an effort to determine exactly how much money Bottolfson, and the entities controlled by him, have received from investors and what has happened to this money, NFA has made repeated requests over the past several weeks for records relative to these entities but, to date, Bottolfson has failed to comply with NFA's requests. As such, Bottolfson has failed to cooperate with NFA in its investigation of his activities and the activities of the entities controlled by him, and has impeded NFA's efforts to determine the identity of individuals who invested with him, the amount they invested, and what has happened to their investments.

The MRA and ARA will remain in effect until such time as Bottolfson and Spirit 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 August 27, 2010, NFA issued a Member Responsibility Action ("MRA") against Spirit Investments, Inc. and an Associate Responsibility Action ("ARA") against Scott A. Bottolfson whereby:

1. Bottolfson and Spirit are prohibited from soliciting or accepting any funds from customers or investors, soliciting investments for any commodity pools or other investment vehicles, or placing any trades on behalf of customers, commodity pools, or investors except liquidation or risk reducing trades in Kingship Commodities Group LP ("Kingship Fund"), Increase Investments, Inc., or any other fund, accounts or investment vehicles over which Bottolfson exercises control;

2. Bottolfson and Spirit are prohibited from disbursing or transferring any funds of customers, investors, commodity pools over which they exercise control, or participants in any such commodity pools, without prior approval from NFA; and

3. Bottolfson and Spirit are required to provide copies of this MRA/ARA via overnight courier to all: a) customers; b) participants in the Kingship Fund and Increase Investments, Inc. and all investors in any other funds or investment vehicles over which Bottolfson and/or Spirit exercises control; and c) to all banks, brokerage firms, and other financial institutions in which money is on deposit in the name of Spirit, Kingship Fund, Increase Investments, Inc., or any other entity over which Bottolfson exercises control.

This action is effective immediately and is deemed necessary to protect customers of Spirit, Kingship Fund, Increase Investments, Inc., and Bottolfson, as well as investors in commodity pools and other investment vehicles controlled by Spirit and/or Bottolfson, based on the following facts and circumstances: NFA has received information that Bottolfson and Increase Investments, Inc. obtained substantial sums of money from investors (perhaps as much as $6 million from as many as thirty investors) to whom Bottolfson and Increase Investments, Inc. issued promissory notes and represented that investors' money would be used to trade futures. However, Bottolfson had previously represented to NFA auditors that Increase Investments, Inc. only traded physicals and real estate. NFA has now learned that investors who gave money to Bottolfson and/or Increase Investments, Inc. have been advised that most, if not all, of their investments have been lost. In an effort to determine exactly how much money Bottolfson, and the entities controlled by him, have received from investors and what has happened to this money, NFA has made repeated requests over the past several weeks for records relative to these entities but, to date, Bottolfson has failed to comply with NFA's requests. As such, Bottolfson has failed to cooperate with NFA in its investigation of his activities and the activities of the entities controlled by him, and has impeded NFA's efforts to determine the identity of individuals who invested with him, the amount they invested, and what has happened to their investments.

The MRA and ARA will remain in effect until such time as Bottolfson and Spirit have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements.