On December 9, 2009, this NFA issued a Complaint against Torc Investment and Research LLC, an independent introducing broker Member of NFA and a registered broker-dealer, located in New York City. The Complaint alleged that Torc failed to file its December 31, 2007, June 30, 2008 and June 30, 2009 unaudited semi annual financial statements within the time prescribed by NFA Financial Requirements Section 5(b). The Complaint also alleged that Torc failed to file with NFA copies of its March 31, 2008 and September 30, 2009 unaudited quarterly financial statements and its December 31, 2007 audited financial statement, within the time prescribed by NFA Financial Requirements Section 5(c).

Torc submitted an Offer in which, without admitting or denying the allegations, it agreed to pay a fine of $10,000 within 30 days of the effective date of a Decision accepting the Offer. The NFA’s Decision accepting Torc’s Offer will operate to bar any future Complaints by NFA against Torc for the conduct charged in the Complaint in this case.