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| | Brockbank, Love, BIRMA |
 | | While operating BIRMA, Brockbank and Love misappropriated customer funds, commingled investor funds with their own funds, and issued false statements to investors representing that profitable trading had occurred on behalf of the pool when such trading had not occurred. |
 | | Brockbank, Love and BIRMA (collectively referred to as "Defendants") have opened commodity futures trading accounts in the name of BIRMA with at least three futures commission merchants ("FCM") and misappropriated investor funds by depositing the investors' funds into accounts in which Defendants maintained sole financial interest. |
 | | Each failure to establish the BIRMA pool or pools as a separate legal entity from Brockbank, Love or BIRMA, Ltd. during the relevant time period, including but not limited to those specifically alleged herein, is alleged as a separate and distinct violation of Regulation 4.20(a), 17 C.F.R. § 4.20(a). |
| www.cftc.gov /enf/00orders/enfbirma.htm (2173 words) |
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