The NFA alleged that IVG Energy Ltd.
("IVG"), an introducing broker, failed to (i) "keep
full, complete and systematic records of all transactions relating
to IVG's business of dealing in commodity interests," and
(ii) supervise employees' recordkeeping activities.
According to the NFA complaint, IVG violated
NFA Compliance Rule 2-10(a) by failing to maintain pre-trade
communications and trade confirmations, and
NFA Compliance Rule 2-9(a) by failing to supervise
employees' written communications. NFA Compliance Rule 2-10(a)
incorporates CFTC Rules
1.31 and
1.35.
The NFA ordered IVG to submit a written response within thirty
days addressing each allegation set forth in the complaint. The NFA
also listed the "potential penalties, disqualification and
ineligibility" it may impose at the conclusion of the
proceeding.