On August 8, 2005, First International Commodity Group, Inc. ("FICG") will be added to NFA's list of firms that have been disciplined by NFA or the CFTC for sales practice fraud as a result of the firm's settlement of an NFA Complaint against FICG alleging, among other allegations, sales practice fraud. Members should be aware that all former associated persons ("APs") of FICG are considered to have been employed by a disciplined firm.

You should review the requirements of NFA Compliance Rule 2-9 and the related Interpretive Notice, which can be found on NFA's Web site at http://www.nfa.futures.org/nfaManual/manualInterp.asp#21. Please review the complete list of disciplined firms and the employment background of all of your APs to determine the likelihood of your firm qualifying for enhanced supervisory procedures. Terminating one, or more, individual who worked for FICG or any other disciplined firm does not guarantee that your firm will avoid the requirements of this rule. If you terminate APs, you will change the AP structure of your firm, which may trigger the requirement for enhanced supervisory procedures based upon the employment background of other APs.

If you have any questions pertaining to this matter, please contact Jennifer Sunu, Associate Director, Compliance, at (312) 781-2259.