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December 31, 2013
NFA orders Westminster, California commodity trading advisor Cap Ex Partners LLC to permanently withdraw from NFA membership and sanctions its principals, Keith R. Bramlett and Ralph H. Johnson
December 31, Chicago - National Futures Association (NFA) has ordered Cap Ex Partners LLC (Cap Ex), a commodity trading advisor Member of NFA located in Westminster, California, to permanently withdraw from NFA membership. NFA has also ordered Keith R. Bramlett (Bramlett) and Ralph H. Johnson (Johnson), associated persons and listed principals of Cap Ex, to withdraw from NFA membership. Bramlett and Johnson are prohibited from applying for NFA membership or associate membership for a period of two years from the date of their withdrawals. In addition, Bramlett and Johnson are prohibited from acting as a principal of any NFA Member for a period of three years from the date of their withdrawals. The Decision, issued by a designated panel (Panel) of NFA's Hearing Committee, is based on a Complaint filed against Cap Ex, Bramlett and Johnson on August 29, 2013, and a settlement offer submitted by Cap Ex, Bramlett and Johnson.
The Panel found that Cap Ex, Bramlett and Johnson charged their customers excessive fees and failed to provide customers with a break-even analysis as required by NFA rules. In addition, Cap Ex and Bramlett willfully submitted false information to NFA. Further, Cap Ex used a misleading disclosure document, did business with an entity that was required to be registered as a commodity pool operator but was not registered in such capacity and failed to list an entity as a principal of the firm.