Sep 23, 2024 On August 15, 2024, the National Futures Association Committee filed a Complaint against Trinity Trading, a former NFA member and a commodity pool operator/commodity trading advisor (CPO/CTA) based in Orlando, Florida. The Complaint also named Bruce Schock, who was the principal and associated person (AP) of Trinity Trading and a former NFA Associate. The main allegations were that Trinity Trading didn’t keep proper records, failed to distribute disclosure documents, account statements, and certified annual reports to their pool participants, and commingled pool assets—all of which violated NFA Compliance Rule 2-13(a). They also allegedly let unregistered individuals act as APs without being NFA Associates (in violation of NFA Bylaw 301(b)) and didn’t get NFA approval for individuals acting as forex APs (in violation of NFA Bylaw 301(j)). On top of that, the Complaint accused both Trinity Trading and Schock of failing to maintain high standards of commercial honor and equitable trading principles (violating NFA Compliance Rule 2-4). They also reportedly used promotional materials that mentioned profits without discussing the risk of loss and featured video content about future profits without submitting it for NFA review (violating NFA Compliance Rule 2-36(g), as incorporated by Rule 2-39(a)). Lastly, they were accused of failing to supervise properly, which violated NFA Compliance Rule 2-36(e), as incorporated by Rule 2-39(a). Trinity Trading and Schock responded to these allegations with a settlement offer. Without admitting or denying the charges, they proposed the following terms: Trinity Trading agreed not to reapply for NFA membership or act as, or be listed as, a principal of any NFA Member going forward. Schock agreed not to apply for NFA membership, reapply for NFA associate membership, or act as, or be listed as, a principal of any NFA Member in the future. By submitting this offer, they acknowledged that any decision accepting it would include findings that they had committed the violations outlined in the Complaint. After reviewing the settlement offer, the Committee determined that Trinity Trading and Schock did indeed commit the violations they were accused of. The Committee then decided on the following penalties: Trinity Trading will not be allowed to reapply for NFA membership or serve as, or be listed as, a principal of any NFA Member in the future. Schock will also not be allowed to apply for NFA membership, reapply for NFA associate membership, or serve as, or be listed as, a principal of any NFA Member in the future. This decision, along with the settlement offer, can’t be used as the sole basis for any other actions by the NFA against Trinity Trading or Schock, except to enforce the settlement or deny them future NFA membership or principal status. As a result of this decision, under Commodity Futures Trading Commission (CFTC) Regulation 1.63, Schock is permanently ineligible to serve on any disciplinary committee, arbitration panel, oversight panel, or governing board of a self-regulatory organization, as defined in CFTC Regulation 1.63.