Page 35 - 期货和衍生品行业监管动态（2024年9月刊）

期货和衍生品行业监管动态

人行事，违反了 NFA 章程第 301（b）条；还指控 Trinity Trading 和 Schock 在与

Trinity Trading 投资者的交易中未能遵守商业信誉的高标准和公正公平的交易原

则，违反了《NFA 合规规则》第 2-4 条；未能遵守 NFA 的宣传材料要求，违反

了通过《NFA 合规规则》第 2-39（a）条引入的《NFA 合规规则》第 2-36（g）

条。最后，控告书指控 Trinity Trading 和 Schock 未能履行管理职责，违反了通过

《NFA 合规规则》第 2-39（a）条引入的《NFA 合规规则》第 2-36（e）条。

在其决定中，商业行为委员会认定 Trinity Trading 和 Schock 确实构成了控告

书中指控的违规行为。

NFA Orders Florida Firm Trinity Trading Group LLC and Its Principal Not to

Reapply for NFA Membership and Principal Status (2024/9/19)

NFA has ordered Trinity Trading Group LLC (Trinity Trading), a commodity

pool operator and commodity trading advisor and former NFA Member forex firm

located in Orlando, Florida, not to reapply for NFA membership or act or be listed as a

principal of an NFA Member. NFA has also ordered Bruce R. Schock (Schock), a

former NFA Associate and prior principal of Trinity Trading, not to apply for NFA

membership, or reapply for NFA associate membership, or act or be listed as a

principal of an NFA Member.

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 Trinity Trading

and Schock, in which they neither admitted nor denied the allegations in the

Complaint.

Among other charges, the BCC’s Complaint alleged Trinity Trading failed to

create and maintain required records, failed to distribute disclosure documents and

account statements to pool participants, and commingled pool assets, in violation of

NFA Compliance Rule 2-13(a); and permitted unregistered individuals to act as

associated persons without being NFA Associates, in violation of NFA Bylaw 301(b).

The Complaint further alleged Trinity Trading and Schock failed to observe high

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