The NFA Issued a Member Responsibility Action (“MRA”) against Direct Investment Products, Inc. and Institutional Capital Management LLC and an Associate Responsibility Action (“ARA”) against Alexander Glytenko.

1. Glytenko, DIP and ICM are prohibited from soliciting or accepting any funds from customers, or pool participants or investors in any pools or accounts that Glytenko, DIP and ICM operate or over which they exercise control including, but not limited to, Institutional Capital Fund, LLC and DIP Capital Partners, Inc.;

2. Glytenko, DIP and ICM are prohibited from placing trades on behalf of any pools or accounts that they operate or over which they exercise control including, but not limited to, Institutional Capital Fund, LLC and DIP Capital Partners, Inc. except to liquidate existing positions;

3. Glytenko, DIP and ICM are prohibited from disbursing or transferring any funds of customers, or participants or investors in any pools or accounts that they operate or over which they exercise control including, but not limited to, Institutional Capital Fund, LLC and DIP Capital Partners, Inc. without prior approval from NFA; and

4. Glytenko, DIP and ICM are required to provide copies of this MRA/ARA via overnight courier to a) all customers; b) to all pool participants and investors in any pools or accounts that Glytenko, DIP or ICM operate or over which they exercise control including, but not limited to, the participants and investors in Institutional Capital Fund, LLC and DIP Capital Partners, Inc.; and c) to all banks and other financial institutions with which money is on deposit in the name of Institutional Capital Fund, LLC, DIP Capital Partners, Inc. or Glytenko or over which Glytenko, DIP or ICM exercises control.

This action is effective immediately and is deemed necessary to protect customers of Glytenko, ICM and DIP and participants in any pools or accounts that Glytenko, ICM or DIP operate or over which they exercise control based on the failure of Glytenko, DIP and ICM to cooperate with NFA in an examination of DIP and ICM, or demonstrate that they are in full compliance with NFA Requirements.

The MRA will remain in effect until such time as Glytenko, DIP and ICM have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements.