Case Summary

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Chalis, Andhari and Young filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On July 31, 2008, Brueck filed an Answer to the Complaint in which he denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Chalis, Andhari and Young filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Tiger, Ozkan and Golub filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Tiger, Ozkan and Golub filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 22, 2008, Smith, Patton and Spear filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On September 9, 2009, a designated Panel of the Hearing Committee issued a Decision to Patton after a hearing was held. Patton was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member for 60 days. Patton was also ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall 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. Patton shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Patton is an NFA Member, Associate Member or a principal of an NFA Member will be counted.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 22, 2008, Smith, Patton and Spear filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 22, 2008, Smith, Patton and Spear filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Tiger, Ozkan and Golub filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.

COMPLAINT:

On June 30, 2008, NFA issued a Complaint charging Tiger, Ozkan, Golub, Chalis, Andhari, Smith, Patton, Spear, Young and Brueck with making deceptive and misleading sales solicitations and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint also charged Tiger, Ozkan and Golub with failure to supervise.

ANSWER:

On September 19, 2008, Chalis, Andhari and Young filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION:

On July 28, 2009, Tiger was ordered to withdraw from NFA membership on or before August 31, 2009 and never again apply for NFA membership or principal status with any NFA Member. Ozkan was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA membership, associate membership or principal status with any NFA Member for three years. Ozkan was also ordered to withdraw Puma from NFA membership on or before August 31, 2009 and Puma may never apply for NFA membership or principal status with any NFA Member in the future. Should Ozkan apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Ozkan was ordered to pay a $200,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Ozkan for NFA membership, associate membership or principal status with any NFA Member will not be considered or approved unless the fine has been paid in full. Should Ozkan apply for and be approved for NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such an event, he may not ever be a principal of an NFA Member or act in any manner which would require him to be disclosed as a principal of any NFA Member. Should Ozkan not seek NFA associate membership following the expiration of the three-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, then in such case, Ozkan may have a passive investment of 10% or more in an NFA Member firm provided that he not have any involvement in the management of the firm which would require registration as an AP and NFA associate membership, including, but not limited to: 1) exercising a controlling interest over the firm’s regulated activities; and 2) exercising any responsibilities with respect to the regulated operations of the firm. Should Ozkan attain principal status with any NFA Member in compliance with this, he may not ever be an NFA associate member.

Golub was ordered to withdraw from NFA associate membership and principal status with any and all NFA Members on or before August 31, 2009 and not apply for NFA associate membership for six years. Golub may not apply for NFA membership or principal status with any NFA Member at any time in the future. Golub is prohibited from working for any NFA Member, either directly or indirectly, in any compliance capacity involving futures or options on futures at any time in the future.

Chalis was ordered not apply for NFA membership, associate membership or principal status with any NFA Member for ten years. Chalis was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Chalis shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Chalis is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Chalis apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the ten-year period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Chalis was ordered to pay a $25,000 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Chalis for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Andhari, Smith, Brueck and Spear were each ordered to not apply for NFA membership, associate membership or principal status with any NFA Member for a period of one year. Andhari, Smith, Brueck and Spear were ordered to tape record any and all conversations with customers or prospective customers for a period of six months. In addition, they shall cause any and all APs sponsored by any Member of which they are a principal to tape record any and all conversations with customers or prospective customers during that period. Andhari, Smith, Brueck and Spear shall each promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which they are an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Andhari, Smith, Brueck and Spear apply for NFA membership, associate membership or principal status with any NFA Member following the expiration of the one-year period during which they may not apply for NFA membership, associate membership or principal status with any NFA Member, they were each ordered to pay a $7,500 fine to NFA, due and payable in full on or before the date of any such application. Any future application by Andhari, Smith, Brueck and Spear for NFA membership, associate membership or principal status with any NFA Member shall not be considered or approved unless the fine has been paid in full.

Young was ordered to withdraw from NFA associate membership on or before September 30, 2009 and not apply for NFA associate membership, membership or principal status with any NFA Member for six months. Young was ordered to tape record any and all conversations with customers or prospective customers for six months. In addition, he shall cause any and all APs sponsored by any Member of which he is a principal to tape record any and all conversations with customers or prospective customers during that period. Young shall promptly produce any and all recordings to NFA in a manner in which the participants and dates of the conversations can be readily identified. Only periods during which Young is an NFA Member, Associate Member or a principal of an NFA Member will be counted. Should Young attain NFA membership, associate membership or principal status with any NFA Member following the expiration of the six-month period during which he may not apply for NFA membership, associate membership or principal status with any NFA Member, Young was ordered to pay a $25,000 fine to NFA after his attainment of any such status.