The NFA ordered Leonard Daniel Locricchio of Europa Capital Associates LLC to withdraw from NFA membership and associate membership and not apply for NFA membership or act as a principal of an NFA Member for two years. In addition, Locricchio was ordered not to reapply for NFA associate membership for six months. A June 30, 2009 Complaint charged Locricchio with acting as a CTA without being registered as a CTA; failing to obtain written authorization to exercise discretion over customer accounts; providing false or misleading information to NFA; and failing to observe high standards of commercial honor and just and equitable principles of trade. He answered the allegations and also submitted an Offer, wherein he neither admitted nor denied the allegations. The Offer was accepted.