Page 18 - 期貨和衍生品行業監管動態（2024年8月刊）

期貨和衍生品行業監管動態

(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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