The National Futures Association ordered Hardee Brothers LLC, an NFA member commodity pool operator and commodity trading advisor, to withdraw from membership and never reapply. It also ordered Sidney Curtis Hardee, an associated person and principal of the firm, to withdraw and never apply for NFA membership again or reapply for associate membership or principal status with an NFA member. The action was taken through a Business Conduct Committee decision based on a committee complaint and a settlement offer in which Hardee Brothers and Hardee neither admitted nor denied the allegations. The complaint alleged violations of NFA Compliance Rules 2-2 and 2-4, including deceitful conduct, misappropriation of customer funds and willfully providing misleading information to NFA. It also alleged that the firm solicited a customer using a disclosure document that NFA had not reviewed and accepted and commingled pool assets with firm assets, in violation of Compliance Rule 2-13.