What was his mistake? This system has some good points to it, however, Arnold made it appear to perform better than it actually did. The CFTC is cracking down on trading system vendors that use hypothetical results and try to make it look as if they actually made these returns trading a real account. Respondents also acted as CTAs by providing PPS trading signals to two commodity pools, one from and one from Since at least , Respondents also have offered and sold to the public a publication entitled Systems USA, distributed by mail and over the Internet.

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What was his mistake? This system has some good points to it, however, Arnold made it appear to perform better than it actually did. The CFTC is cracking down on trading system vendors that use hypothetical results and try to make it look as if they actually made these returns trading a real account.
Respondents also acted as CTAs by providing PPS trading signals to two commodity pools, one from and one from Since at least , Respondents also have offered and sold to the public a publication entitled Systems USA, distributed by mail and over the Internet.
Systems USA purports to "track" the performance of various trading systems authored by Arnold and other vendors, and offers and sells these systems and services related to these systems. Respondents distributed direct-mail promotional literature through two publishers in and and directly in Arnold has periodically engaged in mass-mailings to promote his system, and has sent out, or caused others to send out, promotional material for PPS products to at least 50, prospective clients.
The Promotion A second publisher prepared and distributed promotional material to between 45, and 90, people in , which offered for sale the PPS training video and computer software.
This promotion contained the same three fraudulent representations discussed above that were made in the Promotion.
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