NFA ordered a former CPO and CTA (i.e., Almas Capital Management LLC ("Almas Capital")), along with its former sole principal, not to reapply for NFA membership or act as a principal of a member. NFA's decision was based on a Complaint by NFA's Business Conduct Committee and a settlement offer submitted by Almas Capital and its former principal Mark Nichols in which "neither admitted nor denied the allegations." The Complaint alleged that Almas Capital and Mr. Nichols failed to cooperate with NFA during its 2018 examination.

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