NFA Financial Requirements Section 5, in pertinent part, that Member lBs that
are not operating pursuant to a guarantee agreement must maintain Adjusted
Net Capital (‘ANC) equal to or in excess of the greatest of:
(i) For Member lBs with less than $1,000,000 in ANC, $6,000 per office
operated by the lB (including the main office); or
(ii) For Member lBs with less than $1,000,000 in ANC, $3,000 for each AP sponsored by the lB.
In a June 10, 2009 complaint, the NFA charged that Dynamic Online Trading Inc. and George Kerr, its sole AP, violated these and other requirements. The NFA Hearing Panel accepted an offer made by Kerr and DOT under which they are ordered to pay a $7,500 fine. In addition, DOT and any firm of which Kerr is a principal are ordered to only operate as a GIB for thirty months.