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1
.
COMPLAINT
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EXTRACTED KEY WORDS
PIERCE COMMISSION VIOLATION ACT REGULATION RESPONDENT COMMODITY ADVERTISEMENTS PROFITS FUTURES TIME PERIOD CUSTOMERS PURSUANT TRADES SUBSCRIBERS ALLEGES RELEVANT TIME PERIOD CHART TRADERS INTERNET CTAS REPRESENTATIVES ALLEGATIONS FRAUDULENT WEBSITES MISREPRESENTATIONS TRADING ADVISOR CLIENT PROCEEDING TRANSACTION |
UNITED STATES OF AMERICA
Before the
COMMODITY FUTURES TRADING COMMISSION
:
In the Matter of : CFTC Docket No. 02-15
:
Stephen
Alan
Pierce,
: COMPLAINT
AND
NOTICE
individually and : OF HEARING PURSUANT TO
d/b/a Rapid Fire Swing Trading and : SECTIONS 6(c), 6(d) AND 8a(4)
The Chart Traders, : OF THE COMMODITY
: EXCHANGE
ACT,
AS
AMENDED
:
Respondent.
:
___________________________________ :
I.
The Commodity Futures Trading Commission ("Commission") has received information
from its staff that tends to show, and the Commission's Division of Enforcement ("Division")
alleges, that:
SUMMARY
1. During the time period of at least March 2000 through the present (the "relevant
time period"), Stephen Alan Pierce, individually and d/b/a "Rapid Fire Swing Trading and Chart
Traders" ("Pierce"), a registered commodity trading advisor ("CTA"), used misleading and
fraudulent advertising to solicit customers to purchase commodity futures trading
recommendations over the internet. He fraudulently touted huge profits from use of his systems
and mischaracterized the performance record of the systems as being based on actual trades,
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