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.

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