KANNE, Circuit Judge.
Judd Hirschberg's floor broker registration was revoked after he was convicted of mail fraud in 1991. In 2000, he received a presidential pardon for that conviction, but the Commodity Futures Trading Commission ("CFTC") nevertheless denied his post-pardon application for floor broker registration. Because a pardon does not eliminate the legal determination that Hirschberg was guilty of the crime of which he was convicted, and the crime was
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