This section contains the nature of the case and procedural background.

In 1983 P began accepting and fulfilling paid subscriptions for a commodity market forecast newsletter. P formed three corporations for the provision of commodity services. These corporations provided consulting services, seminar programs, written reports, telephone and telex newsline messages, and account management services. D filed an administrative complaint charging P and the companies with failure to register as commodity trading advisors, to deliver required disclosure documents to clients, and to maintain proper records. The ALJ issued a finding that P and all three corporations liable on all counts charged in both dockets and proposing sanctions. After a hearing, the ALJ reaffirmed the findings of fact and conclusions of law contained in his Initial Decision and imposed the tentative sanctions. P and the corporations appealed, and D reversed the ALJ's finding that P was individually liable for the violations alleged in the first complaint. The Commission affirmed the findings under the second complaint, including P's liability for PEC's and EPC's violations. P appealed. P complains that D did not meet the requirements of the APA because it did not provide 'an adequate statement of . . . findings and conclusions, and the reasons or basis therefor, on all the material issues of fact, law, or discretion presented on the record.'

The legal issues presented in this case will be displayed here.

The court's holding and decision will be displayed here.

Legal analysis from Dean's Law Dictionary will be displayed here.