UNITED STATES OF AMERICA
Before the
COMMODITY FUTURES TRADING COMMISSION

Our review of the record and the parties' appellate submissions establishes that the findings and conclusions of the presiding officer are supported by the weight of the evidence; we therefore adopt them. We further conclude that the presiding officer committed no error material to the outcome of this proceeding and that the parties have not raised important questions of law or policy meriting extended discussion. Accordingly, we affirm the result of the initial decision without opinion.