“Once the Commission has promulgated a trade regulation rule, anyone who violates the rule ‘with actual knowledge or knowledge fairly implied on the basis of objective circumstances that such act is unfair or deceptive and is prohibited by such rule’ is liable for civil penalties of up to ...
ITEM 9 DISCIPLINARY INFORMATION Criminal or Civil Proceedings The Adviser has no material civil or criminal actions to report. Administrative Proceedings Before Regulatory Authorities The Adviser has no material proceedings before regulatory authorities to report. Self-Regulatory Organization ("SRO") ...