|**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**
NOTICE OF MEMBER RESPONSIBILITY ACTION:
On April 6, 2007, NFA issued a Member Responsibility Action ("MRA") to CIS whereby:
1. CIS is suspended from NFA membership effective immediately and until further notice;
2. CIS is prohibited from acting in any manner which requires registration under the Commodity Exchange Act;
3. CIS is prohibited from soliciting or accepting any additional customer accounts;
4. CIS is prohibited from accepting or placing trades for accounts except for liquidation of existing positions. In placing such liquidation orders, CIS must act in the best interest of their customers;
5. CIS is prohibited from distributing, disbursing, or transferring any funds without the prior approval of NFA;
6. CIS is required to provide copies of this MRA overnight courier to all individuals and entities from whom CIS received monies for purposes of trading on-exchange or off-exchange futures and forex and to all financial institutions, including without limitation any futures commission merchants or broker-dealers, to whom CIS has introduced customer accounts.
This action is effective immediately and is deemed necessary to protect customers based on information received by NFA suggesting that CIS – which is only registered as an IB – is illegally acting as a futures commission merchant and as a counterparty to forex transactions. As further grounds for this action, NFA alleges that CIS and its representatives have made misleading and contradictory statements to NFA about its customer business. In this regard, CIS represented to NFA auditors that it does not have any customers; yet, at least two individuals advised NFA that they have had forex trading accounts with CIS since the Fall of 2006, that they are aware of other individuals who have opened accounts with CIS, and that they, themselves, have also solicited customers to open forex trading accounts with CIS. In addition, CIS has failed to cooperate with NFA and has refused to produce bank records and other documents to NFA to enable NFA to confirm if and to what extent CIS is conducting customer business.
The MRA will remain in effect until such time as CIS has demonstrated to the satisfaction of NFA that it is in complete compliance with all NFA Requirements.