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      Page 18 - 期貨和衍生品行業(yè)監(jiān)管動態(tài)(2024年8月刊)
      P. 18

      期貨和衍生品行業(yè)監(jiān)管動態(tài)
      
      
      
      
                         (2024/7/29)
      
      
                              NFA has ordered Turing FX LLC (Turing) and Rockhill Capital Management
      
                         LLC (Rockhill), NFA Member commodity pool operators located in Chicago, Ill., not
      
                         to reapply for NFA membership or act as a principal of an NFA Member at any time in
      
                         the future. NFA has also ordered Christian Hillenbrand, the sole principal and
      
                         associated person of both Turing and Rockhill, to withdraw from, and not reapply for,
      
                         NFA membership status for seven years and to comply with other requirements and
      
                         undertakings, including paying a $150,000 fine if he seeks to reapply for NFA
      
                         membership in the future.
      
      
                              The Decision, issued by NFA’s Business Conduct Committee (BCC), is based on
      
                         a Complaint issued by the BCC and a settlement offer submitted by Turing, Rockhill
      
                         and Hillenbrand, in which they neither admitted nor denied the allegations in the
      
                         Complaint. The Complaint alleged that, among other things, Turing and Rockhill
      
                         permitted the pools they operated to make improper advances of pool assets to Turing
      
                         and Rockhill and failed to deliver NFA-accepted Disclosure Documents to
      
                         participants in the pools they operated prior to accepting participants’ subscriptions.
      
                         The Complaint also alleged that Turing, Rockhill and Hillenbrand failed to observe
      
      
                         high standards of commercial honor and just and equitable principles of trade
                         regarding their use of the pools’ assets. Further, the Complaint alleged that Rockhill
      
      
                         and Hillenbrand provided NFA and the participants in the pool operated by Rockhill
      
                         with false and misleading information as to the pool’s net asset value. In its Decision,
      
                         the BCC found that Turing, Rockhill and Hillenbrand violated NFA Compliance Rule
      
                         2-4, that Turing and Rockhill violated NFA Compliance Rules 2-45 and 2-13, and that
      
                         Rockhill and Hillenbrand violated NFA Compliance Rule 2-2(f).
      
      
                              The complete text of the Complaint and Decision can be viewed on NFA’s
      
                         website.
      
      
                         https://www.nfa.futures.org/news/newsRel.asp?ArticleID=5667
      
      
      
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