Investall, Inc.

Allegations: ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH IN CONNECTION WITH A CIVIL ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC, A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS. Status: Final Summary: ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH, THE CHIEF TECHNOLOGY OFFICER OF ALLOCATERITE, INC., IN CONNECTION WITH A CIVIL ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC, A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS, THEREUNDER. THE ORDER IMPOSED A $200,000 CIVIL PENALTY, A PERMANENT INJUNCTION FROM FUTURE VIOLATIONS OF CERTAIN PROVISIONS OF THE COMMODITY EXCHANGE ACT AND AN INJUNCTION FROM ENGAGING IN ANY ACTIVITY RELATED TO TRADING IN ANY COMMODITY (AS DEFINED IN SECTION 1A(4) OF THE COMMODITY EXCHANGE ACT). IN HIS ROLE AT ALLOCATERITE, SHAH SERVES AS CHIEF TECHNOLOGY OFFICER AND DOES NOT INTERFACE WITH ALLOCATERITE'S CLIENTS, ALL OF WHOM ARE THEMSELVES REGISTERED INVESTMENT ADVISERS, EXCEPT AS REQUIRED TO ANSWER QUESTIONS REGARDING THE MODEL HE CREATED.. SHAH'S ROLE IS TO DEVELOP AND MAINTAIN THE COMPUTER-GENERATED ALGORITHMIC MODEL AND OTHER ALLOCATERITE TECHNOLOGY. IT SHOULD ALSO BE NOTED THAT ALLOCATERITE DOES NOT MAINTAIN CUSTODY OF ANY CLIENT ASSETS, ONLY INTERFACES WITH ITS INVESTMENT ADVISER CLIENTS (AND NOT WITH THE UNDERLYING CLIENTS OF THOSE INVESTMENT ADVISORS), AND DOES NOT HAVE ANY DISCRETIONARY FUNCTIONS WITH RESPECT TO CLIENT ASSETS.

Allegations: NFA CASE NO. 04-BCC-017, NOVEMBER 30, 2004: HAVING REVIEWED THE INVESTIGATIVE REPORT SUBMITTED BY THE COMPLIANCE DEPARTMENT OF THE NATIONAL FUTURES ASSOCIATION ("NFA"), AND HAVING FOUND REASON TO BELIEVE THAT NFA REQUIREMENTS WERE BEING, HAVE BEEN OR ABOUT TO BE VIOLATED AND THAT THE MATTER SHOULD BE ADJUDICATED, NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") ISSUED A COMPLAINT AGAINST ABBAS A. SHAH. THE NFA ALLEGED THAT SHAH VIOLATED NFA COMPLIANCE RULES 2-2(C), 2-2(F) AND 2-5. THE NFA ALLEGED THAT SHAH WAS AN NFA ASSOCIATE AND AN ASSOCIATED PERSON ("AP") AND PRINCIPAL OF THE COMMODITY POOL OPERATOR ("CPO") NFA MEMBER. THE NFA ALLEGED THAT SHAH PROVIDED FALSE AND MISLEADING INFORMATION TO FUND PARTICIPANTS AND NFA AND FAILED TO COOPERATE WITH NFA IN THE COURSE OF AN NFA AUDIT. Status: Final Sanction Detail: PERMANENT Summary: ON MARCH 3, 2011, A NATIONAL FUTURES ASSOCIATION ("NFA") HEARING PANEL ("PANEL") ISSUED A DECISION ("DECISION") AS TO LINUXOR ASSET MANAGEMENT LLC AND ABBAS A. SHAH (COLLECTIVELY, "RESPONDENTS"). SHAH IS THE CHIEF TECHNOLOGIST OF ALLOCATERITE. THE DECISION STATED THAT THE BUSINESS CONDUCT COMMITTEE ("BCC") HAD ISSUED A COMPLAINT AGAINST THE RESPONDENTS. THE BCC ALLEGED THE RESPONDENTS VIOLATED NFA RULES BY SENDING FALSE AND MISLEADING EMAILS, FAILING TO COOPERATE WITH AN AUDIT, FAILING TO PROPERLY REGISTER AN ENTITY AND DEMONSTRATE A PARTICIPANT WAS A QUALIFIED ELIGIBLE PARTICIPANT, FAILING TO ISSUE STATEMENTS AND REPORTS. THE DECISION STATED THAT AN OFFER WAS SUBMITTED BY RESPONDENTS IN WHICH, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, THEY PROPOSED TO SETTLE THE MATTER. PURSUANT TO THE SETTLEMENT OFFER, THE PANEL ORDERED RESPONDENTS TO NEVER AGAIN APPLY FOR NFA MEMBERSHIP OR ASSOCIATE MEMBERSHIP OR ACT AS PRINCIPALS OF AN NFA MEMBER. THE DECISION DID NOT MAKE ANY FINDINGS THAT RESPONDENTS VIOLATED NFA RULES AND NO FINES WERE ASSESSED. THE DECISION SETTLED ALL MATTERS BETWEEN RESPONDENTS AND THE NFA; AND BARS ANY FUTURE MEMBER RESPONSIBILITY ACTIONS OR BCC COMPLAINTS AGAINST RESPONDENTS; AND RESOLVED AND TERMINATED ALL PENDING COMPLAINTS, INVESTIGATIONS AND AUDITS.

Allegations: ON DECEMBER 17, 2008, A CONSENT ORDER OF PERMANENT INJUNCTION AND OTHER EQUITABLE RELIEF WAS ENTERED AGAINST ABBAS A. SHAH IN CONNECTION WITH A CIVIL ACTION BROUGHT BY THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") IN THE SOUTHERN DISTRICT OF NEW YORK. THE ORDER SET FORTH ADMITTED FINDINGS OF FACT AND CONCLUSIONS OF LAW, THAT WHILE AN OWNER AND PRINCIPAL OF LINUXOR ASSET MANAGEMENT LLC, A REGISTERED COMMODITY POOL OPERATOR, SHAH FAILED TO PROPERLY VALUE THE LINUXOR GLOBAL MACRO FUND, FAILED TO SEND TO FUND PARTICIPANTS REQUIRED QUARTERLY STATEMENTS FOR 2002 TO 2004 AND A TIMELY ANNUAL REPORT FOR 2002, AND COMMINGLED PARTICIPANTS' FUNDS WITH THE PROPERTY OF OTHERS, IN VIOLATION OF THE COMMODITY EXCHANGE ACT AND CFTC REGULATIONS THEREUNDER. THIS CONSENT ORDER STIPULATED TO THE FACTS DESCRIBED ABOVE. THE CFTC FILED ITS NOTICE OF ITENNT TO REVOKE REGISTRATION BASED ON THE CONSENT ORDER, WHICH ORDER WAS GRANTED ON A DEFAULT JUDGMENT. Status: Final Sanction Detail: PERMANENT REVOCATION OF REGISTRATION WITH THE CFTC Summary: FINAL