UNITED STATES OF AMERICA
Before the
Commodity Futures Trading Commission

Global Futures Holdings, Inc.,

v.

National Futures Association

CFTC Docket No. CRAA 99-2

ORDER OF SUMMARY AFFIRMANCE

Our review of the record and the parties' appellate submissions establishes that the findings and conclusions of the National Futures Association ("NFA") are supported by the weight of the evidence; we therefore adopt them. We further conclude that NFA committed no error material to the outcome of this proceeding and that the parties generally have not raised important questions of law or policy that merit extended discussion. Accordingly, we affirm NFA's decision without opinion.

IT IS SO ORDERED

By the Commission (Chairman RAINER, and Commissioners HOLUM, SPEARS, NEWSOME, and ERICKSON).

Jean A. Webb
Secretary of the Commission
Commodity Futures Trading Commission

Dated: December 16, 1999