On April 13,2015, the Committee issued a Complaint charging commodity trading advisor NFA Member K & M with failing to enact required procedures regarding allocations from bunched orders, in violation of NFA Compliance Rule 2-10' The Complaint also charged Kaelin and Morrissey with failing to diligently supervise K & M's operations, in violation of NFA Compliance Rule 2-9(a).

OFFER OF SETTLEMENT The Respondents submitted their Offer in which they agreed that they would pay a fine to NFA in the amount of $105,000. ln making their Offer, the Respondents neither admitted nor denied the allegations made against them in the Complaint.