Case Summary

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION UNDER NFA COMPLIANCE RULE 3-15

National Futures Association (“NFA”) hereby gives notice to M25 Investments, Inc. ("M25") and M37 Investments LLC ("M37"), commodity trading advisor ("CTA") Members of National Futures Association, located in Waxahachie, Texas; David P. Fearis, III ("Fearis"), president and an associated person ("AP") of M25, director and AP of M37, and an NFA Associate; and Ronald Lynn Larson ("Larson"), president and an AP of M37, and an NFA Associate, that pursuant to NFA Compliance Rule 3-15, the President of NFA, with the concurrence of NFA’s Executive Committee, has taken a Member Responsibility Action (“MRA”) against M25 and M37, and an Associate Responsibility Action ("ARA") against Fearis and Larson, whereby:

1. M25, M37, Fearis, and Larson are prohibited from soliciting or accepting any funds from customers and investors, or any loans from lenders, other than financial institutions, without prior approval of NFA;

2. M25, M37, Fearis, and Larson are prohibited from placing any futures trades or off-exchange foreign currency trades for themselves or for customers, except to liquidate existing positions;

3. M25, M37, Fearis, and Larson are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts), which are in the names of M25 or M37 or which are controlled by either M25 or M37, without prior approval from NFA; and

4. M25, M37, Fearis, and Larson are required to provide copies of this MRA via overnight courier to a) all customers, b) all investors, and c) all persons and entities to whom it has issued promissory notes, and d) to all banks, brokerage firms, and other financial institutions with which money is on deposit in the name of M25 and M37, or over which M25 or M37 exercises control.

This action is effective immediately and is deemed necessary to protect the investing public and the futures markets based on evidence that M25 and M37 are operating a ponzi scheme whereby they have obtained hundreds of loans from unsophisticated persons who are solicited, among other ways, at or through churches, and in return gave these persons unsecured promissory notes in which M25 and M37 promise to repay the loans with interest. However, the principals of M25 and M37, including Fearis and Larson, appear to have funneled much of the money borrowed from these persons to other entities controlled by them, which are non-NFA Members, and, at present, there appears to be an approximate $3.7 million shortfall between what is owed to note holders and what M25 and M37's own in combined assets. M25, M37, Fearis, and Larson continue to solicit loans from persons even though they have insufficient assets to repay the debt on existing loans, let alone new loans. In soliciting persons to make loans to them, M25, M37, Fearis, and Larson have used misleading promotional material that suggests that M37 has made large sums of money trading when, in fact, M25 and M37 have lost money.

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION UNDER NFA COMPLIANCE RULE 3-15

National Futures Association (“NFA”) hereby gives notice to M25 Investments, Inc. ("M25") and M37 Investments LLC ("M37"), commodity trading advisor ("CTA") Members of National Futures Association, located in Waxahachie, Texas; David P. Fearis, III ("Fearis"), president and an associated person ("AP") of M25, director and AP of M37, and an NFA Associate; and Ronald Lynn Larson ("Larson"), president and an AP of M37, and an NFA Associate, that pursuant to NFA Compliance Rule 3-15, the President of NFA, with the concurrence of NFA’s Executive Committee, has taken a Member Responsibility Action (“MRA”) against M25 and M37, and an Associate Responsibility Action ("ARA") against Fearis and Larson, whereby:

1. M25, M37, Fearis, and Larson are prohibited from soliciting or accepting any funds from customers and investors, or any loans from lenders, other than financial institutions, without prior approval of NFA;

2. M25, M37, Fearis, and Larson are prohibited from placing any futures trades or off-exchange foreign currency trades for themselves or for customers, except to liquidate existing positions;

3. M25, M37, Fearis, and Larson are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts), which are in the names of M25 or M37 or which are controlled by either M25 or M37, without prior approval from NFA; and

4. M25, M37, Fearis, and Larson are required to provide copies of this MRA via overnight courier to a) all customers, b) all investors, and c) all persons and entities to whom it has issued promissory notes, and d) to all banks, brokerage firms, and other financial institutions with which money is on deposit in the name of M25 and M37, or over which M25 or M37 exercises control.

This action is effective immediately and is deemed necessary to protect the investing public and the futures markets based on evidence that M25 and M37 are operating a ponzi scheme whereby they have obtained hundreds of loans from unsophisticated persons who are solicited, among other ways, at or through churches, and in return gave these persons unsecured promissory notes in which M25 and M37 promise to repay the loans with interest. However, the principals of M25 and M37, including Fearis and Larson, appear to have funneled much of the money borrowed from these persons to other entities controlled by them, which are non-NFA Members, and, at present, there appears to be an approximate $3.7 million shortfall between what is owed to note holders and what M25 and M37's own in combined assets. M25, M37, Fearis, and Larson continue to solicit loans from persons even though they have insufficient assets to repay the debt on existing loans, let alone new loans. In soliciting persons to make loans to them, M25, M37, Fearis, and Larson have used misleading promotional material that suggests that M37 has made large sums of money trading when, in fact, M25 and M37 have lost money.

ANSWER:

On October 22, 2009, Larson filed an answer to the MRA.

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION UNDER NFA COMPLIANCE RULE 3-15

National Futures Association (“NFA”) hereby gives notice to M25 Investments, Inc. ("M25") and M37 Investments LLC ("M37"), commodity trading advisor ("CTA") Members of National Futures Association, located in Waxahachie, Texas; David P. Fearis, III ("Fearis"), president and an associated person ("AP") of M25, director and AP of M37, and an NFA Associate; and Ronald Lynn Larson ("Larson"), president and an AP of M37, and an NFA Associate, that pursuant to NFA Compliance Rule 3-15, the President of NFA, with the concurrence of NFA’s Executive Committee, has taken a Member Responsibility Action (“MRA”) against M25 and M37, and an Associate Responsibility Action ("ARA") against Fearis and Larson, whereby:

1. M25, M37, Fearis, and Larson are prohibited from soliciting or accepting any funds from customers and investors, or any loans from lenders, other than financial institutions, without prior approval of NFA;

2. M25, M37, Fearis, and Larson are prohibited from placing any futures trades or off-exchange foreign currency trades for themselves or for customers, except to liquidate existing positions;

3. M25, M37, Fearis, and Larson are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts), which are in the names of M25 or M37 or which are controlled by either M25 or M37, without prior approval from NFA; and

4. M25, M37, Fearis, and Larson are required to provide copies of this MRA via overnight courier to a) all customers, b) all investors, and c) all persons and entities to whom it has issued promissory notes, and d) to all banks, brokerage firms, and other financial institutions with which money is on deposit in the name of M25 and M37, or over which M25 or M37 exercises control.

This action is effective immediately and is deemed necessary to protect the investing public and the futures markets based on evidence that M25 and M37 are operating a ponzi scheme whereby they have obtained hundreds of loans from unsophisticated persons who are solicited, among other ways, at or through churches, and in return gave these persons unsecured promissory notes in which M25 and M37 promise to repay the loans with interest. However, the principals of M25 and M37, including Fearis and Larson, appear to have funneled much of the money borrowed from these persons to other entities controlled by them, which are non-NFA Members, and, at present, there appears to be an approximate $3.7 million shortfall between what is owed to note holders and what M25 and M37's own in combined assets. M25, M37, Fearis, and Larson continue to solicit loans from persons even though they have insufficient assets to repay the debt on existing loans, let alone new loans. In soliciting persons to make loans to them, M25, M37, Fearis, and Larson have used misleading promotional material that suggests that M37 has made large sums of money trading when, in fact, M25 and M37 have lost money.

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION UNDER NFA COMPLIANCE RULE 3-15

National Futures Association (“NFA”) hereby gives notice to M25 Investments, Inc. ("M25") and M37 Investments LLC ("M37"), commodity trading advisor ("CTA") Members of National Futures Association, located in Waxahachie, Texas; David P. Fearis, III ("Fearis"), president and an associated person ("AP") of M25, director and AP of M37, and an NFA Associate; and Ronald Lynn Larson ("Larson"), president and an AP of M37, and an NFA Associate, that pursuant to NFA Compliance Rule 3-15, the President of NFA, with the concurrence of NFA’s Executive Committee, has taken a Member Responsibility Action (“MRA”) against M25 and M37, and an Associate Responsibility Action ("ARA") against Fearis and Larson, whereby:

1. M25, M37, Fearis, and Larson are prohibited from soliciting or accepting any funds from customers and investors, or any loans from lenders, other than financial institutions, without prior approval of NFA;

2. M25, M37, Fearis, and Larson are prohibited from placing any futures trades or off-exchange foreign currency trades for themselves or for customers, except to liquidate existing positions;

3. M25, M37, Fearis, and Larson are prohibited from disbursing or transferring any funds from any accounts (bank, trading, or any other types of accounts), which are in the names of M25 or M37 or which are controlled by either M25 or M37, without prior approval from NFA; and

4. M25, M37, Fearis, and Larson are required to provide copies of this MRA via overnight courier to a) all customers, b) all investors, and c) all persons and entities to whom it has issued promissory notes, and d) to all banks, brokerage firms, and other financial institutions with which money is on deposit in the name of M25 and M37, or over which M25 or M37 exercises control.

This action is effective immediately and is deemed necessary to protect the investing public and the futures markets based on evidence that M25 and M37 are operating a ponzi scheme whereby they have obtained hundreds of loans from unsophisticated persons who are solicited, among other ways, at or through churches, and in return gave these persons unsecured promissory notes in which M25 and M37 promise to repay the loans with interest. However, the principals of M25 and M37, including Fearis and Larson, appear to have funneled much of the money borrowed from these persons to other entities controlled by them, which are non-NFA Members, and, at present, there appears to be an approximate $3.7 million shortfall between what is owed to note holders and what M25 and M37's own in combined assets. M25, M37, Fearis, and Larson continue to solicit loans from persons even though they have insufficient assets to repay the debt on existing loans, let alone new loans. In soliciting persons to make loans to them, M25, M37, Fearis, and Larson have used misleading promotional material that suggests that M37 has made large sums of money trading when, in fact, M25 and M37 have lost money.