2015-01-27

The fallout from a Jan 15 decoupling of a Swiss franc from a euro by a Swiss National Bank continued to have regulatory and authorised reverberations final week. In addition, Chicago Mercantile Exchange Group exchanges resolved a cornucopia of disciplinary actions touching on manners associated to retard trades, programmed trade systems, disruptive trades and rinse sales. As a result, a following matters are lonesome in this week’s Bridging a Week:

Swiss Franc-Euro Decoupling Spurs Worldwide Legal and Regulatory Fallout;

Futures Traders Sanctioned by CME Group Exchanges for Problematic Block Trades, ATS Breakdown, Disruptive Trading, Wash Sales and Other Violations (includes Compliance Weeds);

SEC and Two States Sanction SP for Misconduct Related to Ratings of Commercial-Backed Securities;

FCA Fines and Bans Two Former Senior Executives of Martin Brokers for Contributing to an Unsatisfactory Corporate Culture (includes Culture and Ethics);

CME Group Amends Rule Formally to Prohibit Intraday Violations of Position Limits; Eliminates Provision Dealing With Bids and Offers (includes Compliance Weeds);

Broker-Dealer Sanctioned by FINRA for Sharing Confidential Customer Information in Connection With a Class Action Lawsuit;

CME Group Adds Its View to “Skin in a Game” Debate; and more.

Swiss Franc-Euro Decoupling Spurs Worldwide Legal and Regulatory Fallout

Following a astonishing decoupling by a Swiss National Bank (SNB) of a Swiss franc-Euro sell rate on Jan 15; a successive meteroic arise of a Swiss franc conflicting a euro and, to a obtuse extent, a US dollar; and a financial problem gifted by during slightest dual ubiquitous sell unfamiliar sell dealers, several exchanges and during slightest one regulator instituted a series of hindrance measures and betrothed more.

Among measures taken by exchanges and one regulator:

the National Futures Association augmenting a smallest confidence deposition compulsory to be collected by Forex Dealer Members for trade in 8 unfamiliar currencies by sell clients—including from dual to 5 percent for sell involving Swiss francs (reducing a extent precedence from 50:1 to 20:1);



a row of a Chicago Mercantile Exchange’s Business Conduct Committee, on an puncture basis, postulated additional government to a CME Group Global Command Center per cost fluctuation boundary on certain CME products—including CME unfamiliar sell futures and options. The puncture transformation permits a GCC to cgange a volume of cost extent expansions; mislay cost boundary during any time; and settle possibly a specified trade hindrance will be instituted, among other authority. (Price fluctuation boundary are designed to deter unusual cost movements in markets and can outcome in trade halts underneath certain circumstances. Rules sanctioning such limits for unfamiliar sell futures and options were usually enacted in Dec 2014. Click here for some-more information.) The CME Group also due to rectify a manners to extend a GCC a permanent government “in a comprehensive and solitary discretion, [to] take any transformation it determines compulsory to strengthen marketplace integrity” in a context of cost fluctuation limits, including a form of actions accorded a GCC by a puncture action; and

ICE Futures U.S. augmenting reasonability boundary for all banking span futures contracts. (Reasonability boundary are tough boundary confirmed by ICE Futures U.S. for a electronic trade complement to equivocate fat-finger form errors. Among other effects, orders with bids above or offers next a reasonability extent are not accepted.)

Because of a SNB’s decoupling, during slightest dual firms progressing estimable sell business trade unfamiliar sell gifted poignant waste and collateral issues as a outcome of their clients’ trade losses. This prompted one of a firms (based in a United Kingdom)—Alpari (UK) Limited—to trigger an penury move final week. The other firm, Forex Capital Markets LLC—commonly famous as FXCM—a CFTC-registered sell forex sell dealer, futures elect businessman and provisionally purebred barter dealer—received a US $300 million distillate from Leucadia National Corporation “to accommodate a regulatory-capital mandate and continue normal operations” after losing US $225 million.

In response, Commissioner Sharon Bowen of a Commodity Futures Trading Commission suggested that a CFTC should demeanour into larger law of sell unfamiliar sell dealers:

As we have pronounced before, we have an requirement to forestall a investiture of “gaps” in a regulations. If we find that a partial of a swaps or futures attention is so easily regulated that investors, markets, and a open are being placed in undue risk, we have an requirement to fill that opening and settle a some-more fit and effective regulatory regime…. Specifically, we trust we should cruise substantiating regulations on a sell unfamiliar sell attention that are during slightest as clever as a regulations on a rest of a derivatives industry.

Futures Traders Sanctioned by CME Group Exchanges for Problematic Block Trades, ATS Breakdown, Disruptive Trading, Wash Sales and Other Violations

Exchanges of a Chicago Mercantile Exchange Group imposed countless sanctions conflicting members and nonmembers associated to violations of a cornucopia of manners that residence rinse sales, retard trades and control of a inlet of spoofing, among other taboo conduct. One organisation was also fined in tie with a programmed trade complement breakdown.

Block Trades

According to a germane CME Group business control cabinet (BCC) panels, during several times from Mar 2010 to May 2013 on a Chicago Mercantile Exchange, and from Apr 2010 to Sep 2013 on a Chicago Board of Trade, JP Morgan Securities LLC (1) unsuccessful to news accurate execution times for certain retard trades; (2) unsuccessful to news certain retard trades within compulsory time deadlines; (3) did not keep sequence tickets or other excusable annals of executed retard trades; (4) in one instance, reported an inter-commodity widespread trade as a retard trade when a transaction did not accommodate a smallest apportion threshold for inter-commodity widespread retard trades; and (5) reported dual block-eligible widespread trades in unfamiliar sell futures with particular legs that were not executed during a singular price. In aggregate, JP Morgan concluded to compensate US $115,000 to settle these purported offenses.

Open Position Reporting

JP Morgan also concluded to compensate US $95,000 in sum to solve apart charges associated to a purported disaster to rightly news open seductiveness during a series of spot-month death durations for conflicting futures contracts traded on a CBOT and CME. The germane BCCs claimed a violations occurred since of operational errors, including, in one instance, “an inner comment assignment blunder that placed futures position ensuing from [one] options amends and successive assignments into a wrong subaccount.”

ATS Breakdown

Credit Suisse Securities (USA) LLC concluded to remuneration of a excellent of US$ 175,000 associated to an purported relapse of an programmed trade complement that caused an “excessive” series of sequence and cancel messages on Dec 14, 2012, involving a Mar 2013 Two-Year futures agreement traded on a CBOT. According to a germane BCC, nonetheless Credit Suisse schooled of a malfunction immediately, it available a ATS to continue doing for 90 mins while it endeavored to scold a error. During this time, claimed a BCC, a ATS was obliged for 88% of a messaging volume in a germane futures contract.

Credit Suisse was formerly fined US $150,000 by CME and US $25,000 by ICE Futures U.S. for other ATS breakdowns.

Disruptive Trading

A series of traders staid actions associated to disruptive trade practices.

In one transformation before a New York Mercantile Exchange BCC, Robert Leeds was charged with enchanting in acts “inconsistent with usually and estimable beliefs of trade” for cryptic control on “one or more” occasions between Feb and Jun 2012. According to a BCC, during these times, with a resting sequence on one side of a marketplace involving healthy gas futures contracts, Mr. Leeds would place a vast sequence on a conflicting side of a market, inducing traders to trade with his resting order. Once a resting sequence was hit, he would cancel his vast sequence on a conflicting side “often reduction than a second after it was entered.” In tie with this matter, Mr. Leeds concluded to compensate a excellent of US $40,000, contention to a 15-business day membership cessation and a CME Group products’ trade cessation from Jan 20 by Feb 9.

Mr. Leeds also concluded to a apart US $20,000 fine, another 15-day membership cessation and another CME Group products’ trade cessation from Feb 10 by Mar 3 in a conflicting disciplinary transformation before a Nymex BCC. This matter arose since of allegations that Mr. Leeds, on “one or some-more occasions” between Jan and Apr 2013, entered orders during a pre-opening sessions of a healthy gas futures agreement “that were not for a purpose of executing bona fide transactions.” According to a BCC, “the entrance and successive termination of these orders caused fluctuations in a publicly displayed Indicative Opening Price.”

Similarly, Michael Imperio resolved a disciplinary transformation before a Commodity Exchange, Inc. BCC where it was purported that he entered “numerous” vast orders in a china futures agreement “without a vigilant to trade” on mixed occasions from Jul by Nov 2013. According to a BCC, Mr. Imperio “entered these vast orders to observe a market’s greeting and to inspire marketplace participants to trade conflicting his smaller iceberg orders that were resting on a conflicting side of a book.” Mr. Imperio, allegedly, customarily cancelled his vast orders within one second after his resting iceberg orders were executed. Mr. Imperio concluded to remuneration of a excellent of US $60,000 and a four-week trade entrance suspension. (Iceberg orders—also infrequently called dark apportion or maxshow orders—display on Globex usually a apportionment of an order to a marketplace. After a displayed apportion is executed, another apportionment equal to a executed apportion is suggested as a new sequence during a bottom of a sequence book.)

Likewise, Jonathan Brims and Stephen Gola staid CBOT disciplinary actions where it was purported that, while employees of a CBOT member organisation from Sep 2011 by Dec 2012, they entered vast orders in several CBOT financial futures contracts though a vigilant to trade “to emanate a coming of an imbalance in buy/sell pressure.” They used this appearance, claimed a BCC, to have executed resting orders on a other side of a market. For these offenses, Mr. Gola concluded to compensate a excellent of US $65,000 while Mr. Brims concluded to subtract a excellent of US $50,000. Both Mr. Brims and Mr. Gola concluded to 10-business day CME Group products’ trade suspensions. Another employee—apparently of a same unnamed firm—was formerly authorised for a identical offense.

The control allegedly underlying a disciplinary actions conflicting Mr. Leeds, Mr. Imperio, Mr. Brims and Mr. Gola occurred before to CME Group’s adoption of a denote breach conflicting disruptive practices (Rule 575; click here to access) in Sep 2014. As a result, a respondents were charged with extended prohibitions conflicting enchanting in disgraceful or uncommercial control and/or acts unpropitious to a seductiveness or gratification of a exchange.

Pre-Execution Communications

In another matter, Sunil Arora concluded to compensate a excellent of US $60,000 and to a 30-business day CME Group products’ trade suspension, for channel “numerous” buy and sell patron orders on CME Globex between Jan 2012 and May 2013 successive to pre-execution communications. According to a CME BCC, “in a infancy of these instances,” Mr. Arora possibly did not enter a ask for quote (RFQ) followed by a ask for cranky (RFC), or entered an RFQ or an RFC, though not both.

Wash Sales

Finally, Kaloti Jewellery International DMCC and Tarek El-Mdaka concluded to sanctions by Comex in tie with trades allegedly placed by Mr. El-Mdaka for one comment of Kaloti, while directing other Kaloti traders to trade conflicting him for another comment of Kaloti. This trade was done, claimed a Comex BCC, to tighten out Kaloti positions during one clearing firm. The BCC “found that Mr. El-Mdaka unsuccessful to diligently manipulate these traders in that he was not sensitive with Exchange manners and destined them to rivet in rinse trades.” To solve this matter, Kaloti concluded to compensate a excellent of US $30,000 and Mr. El-Mdaka, to compensate a excellent of US $10,000. Mr. El-Mdaka also concluded to a five-business day trade entrance suspension.

Compliance Weeds: Each of these actions points to a need for repeated training to trade and operations staff per a nuances of sell manners per position stating and trade practices. Moreover, where certain noncompetitive trade is certified by exchanges (e.g., retard trades, sell for associated positions, pre-execution communications), traders contingency also mostly be reminded of a specific mandate of such authorizations. Violations of these mandate potentially violate not usually a germane exchange’s rules, though germane law and manners of a Commodity Futures Trading Commission that demarcate noncompetitive sell unless specifically finished in suitability with certified sell rules.

And briefly:

SEC and Two States Sanction SP for Misconduct Related to Ratings of Commercial-Backed Securities: Standard and Poor’s Rating Services resolved coercion actions by a Securities and Exchange Commission, a New York Attorney General and a Massachusetts Attorney General by similar to compensate sum penalties of US $77 million, among other sanctions—including a one-year time-out from rating certain blurb mortgage-backed bonds (CMBSs). The SEC filed and staid 3 apart coercion actions conflicting SP. One associated to SP’s doing of a methodology for rating certain forms of CMBSs. The SEC charged that SP altered a methodology in 2010 to ask a reduction despotic customary though disclosing this in 8 presale reports released between Feb and Jul 2011. The second SEC coercion transformation associated to a 2012 news display normal blurb loan pool waste of approximately 20% requesting Great Depression levels of mercantile stress. This news was released by SP, pronounced a SEC, to denote “the relations conservatism of a new criteria.” However, a SEC claimed this news was injured since element assumptions were not disclosed, including that underlying information was separate to a Great Depression. Finally, a third SEC coercion transformation associated to SP’s disaster from Oct 2012 by Jan 2014 to say and make adequate inner controls per changes in assumptions used in reviewing certain residential mortgage-backed securities. These assumptions—which were unsuitable with assumptions described by SP publicly, pronounced a SEC—related to estimated waste that would be incurred if a debt defaulted. The Massachusetts and NY Attorneys General also fined SP associated to a “misleading open statements” per a methodology to rate certain CMBSs in 2011.The SEC alone commenced an administrating move conflicting Barbara Duka, who during a germane time, was in assign of SP’s group that published a 8 presale reports associated to a germane CMBSs that were a theme to a several coercion actions. The SEC charged that Ms. Duka “acted with scienter in tie with a fake and dubious CMBS Presales, in that Duka and a CMBS Group knew that a Presales contained false information and intentionally or fast caused such false information to be published.” Previously, Ms. Duka filed an transformation in a federal justice in New York seeking to ask a SEC from commencing a adminstrative transformation conflicting her, claiming that a executive move disregarded her inherent rights. That transformation is pending.

FCA Fines and Bans Two Former Senior Executives of Martin Brokers for Contributing to an Unsatisfactory Corporate Culture: The Financial Conduct Authority fined a former arch executive and arch correspondence officer of Martin Brokers (UK) Limited for correspondence and informative failings during a firm. David Caplin, a former CEO, concluded to compensate a excellent of GBP 210,000 (approximately US $315,000), while Jeremy Kraft, a former CCO, concluded to compensate a excellent of GBP 105,000 (approximately US $155,000). Both people also consented to an sequence prohibiting them from behaving any supposed “significant change function” in tie with any FCA-regulated activity going forward. Both a Commodity Futures Trading Commission and a FCA have formerly staid coercion record conflicting Martin Brokers and, in a box of a CFTC, conflicting RP Martin Holdings Limited too, claiming that a firms participated in a attempted and tangible strategy of a central regulating of a London Interbank Offered Rate from during slightest Sep 2008 by Aug 2009.  According to a FCA, Mr. Caplin was “the widespread celebrity during [Martin Brokers] and his government over a broking organisation was absolute.” In assessing a opening of a firm’s brokers, Mr. Caplin “looked essentially during that [b]roker’s elect and a strength of that [b]roker’s earning potential,” pronounced a FCA. According to a FCA, this enlightenment “ultimately valid to be during a responsibility of regulatory compliance.” In assessing Mr. Kraft’s failings, a FCA remarkable that Mr. Kraft was “pre-occupied” with his vital and operational responsibilities during Martin Broker in further to other responsibilities and so “failed to give due attention” to his responsibilities as arch correspondence officer. Mr. Kraft also failed, pronounced a FCA, sufficient to consider Martin Brokers’ correspondence risks and unsuccessful to keep a FCA and a prototype group sufficient sensitive “of elementary and critical regulatory matters.” According to a matter released by a FCA, “Mr. Kraft and Mr. Caplin were obliged for sourroundings a right enlightenment during Martins and ensuring that a firm’s risk government systems and controls were adequate to conduct a broking activities. They unsuccessful to do this. Proper systems and controls were self-existent and there was a enlightenment during Martins where income came initial and correspondence was seen as insignificant rather than as an constituent partial of a using of a firm.”

Culture and Ethics: Setting a right tinge is some-more than a automatic doing of compulsory manners and regulations. It is a instruction from a house of directors and comparison government that a customary of control is not usually complying with a law, though complying with a suggestion of a law to safeguard that business and counterparties are treated fairly, and that a repute of a organisation is constantly confirmed if not enhanced. we have pronounced it many times—the customary of control for all employees should be a “grandmother test:” don’t rivet in control that would confuse we if your grandmother review about it in a morning publication and after asked about it during breakfast! A really elementary test! Remember: keep grandma proud!

CME Group Amends Rule Formally to Prohibit Intraday Violations of Position Limits; Eliminates Provision Dealing With Bids and Offers: The CME Group is proposing to rectify a manners specifically to demarcate violations of position boundary on an intraday basis. CME Group exchanges have customarily practical a breach conflicting progressing positions in defilement of position boundary (CME Rule 562; click here to access) both on an intraday and end-of-day basis, unchanging with how a Commodity Futures Trading Commission and other exchanges ask their homogeneous prohibitions. Simultaneously, a CME Group is proposing to discharge a denote breach conflicting creation bids or offers that, if accepted, would means a position extent defilement Instead, a sell suggests that such bids or offers competence be deemed “disruptive,” and discordant to a denote breach conflicting disruptive trade or a ubiquitous offense. CME Group’s due amendment is approaching to be effective Feb 6.

Compliance Weeds: CME Group’s due sequence amendments will heed a exchange’s prohibitions with those of a CFTC and ICE Futures U.S. The CME Group is now singular in prohibiting underneath all resources bids or offers that if executed would means a position extent violation.

Broker-Dealer Sanctioned by FINRA for Sharing Confidential Customer Information in Connection With a Class Action Lawsuit: Scottrade, Inc. concluded to compensate a excellent of US $200,000 and several undertakings to solve an coercion transformation brought by a Financial Industry Regulatory Authority per a firm’s purported unapproved pity of information associated to 300,000 business in tie with a category transformation litigation. According to FINRA, on 36 occasions in 2012, Scotttrade disclosed a names and addresses of a business in defilement of an germane sequence of a Securities and Exchange Commission (Regulation S-P; click here for some-more details) that generally prohibits avowal of nonpublic patron information unless a patron receives correct notice and an event to opt out of a disclosure, and manners of FINRA and a prototype (NASD Regulation Inc.). The information was disclosed to a claims director or a private law organisation in tie with a category transformation lawsuit associated to a purchases of Veolia Environnement S.A. American repository shares between Apr 27, 2007, and Aug 4, 2011. Both a claims director and a law organisation had asked Scottrade to brazen a form notice to a germane business or yield a patron information to them. Scottrade opted to brazen a information willingly as a ask was conjunction a summons nor a justice order, pronounced FINRA.

CME Group Adds Its View to “Skin in a Game” Debate: The Chicago Mercantile Exchange Group combined a voice to a discuss about a suitable turn of grant or “skin in a game” a clearinghouse should make to a clearing member default rapids in a white paper it published. Arguing that it is a “misconception” that “central clearing formula in a thoroughness of systemic risks,” CME remarkable that, instead, “risks might be strong within a clearing member by a bearing they move to a [clearinghouse].” Accordingly, says CME, clearinghouses structure default waterfalls “to safeguard they can sufficient conduct a risks brought by clearing members and inspire advantageous balancing of risk among clearing members.” CME reminded that it has “long advocated for meaningful, funded, first-loss contributions to a [clearinghouse] rapids in allege of a mutualized clearing member default fund, and has demonstrated this joining with a possess dedicated capital.” CME pronounced that, as of Sep 30, 2014, a US and UK rapids contributions were US $375 million or approximately 5.25 percent of a sum funded, mutualized default funds. Previously, LCH.Clearnet weighed in on a horde of clearinghouse issues, including what it deliberate an suitable turn of skin in a game, in a white paper it also published. And even some-more briefly:

CFTC Approves Three Foreign Boards of Trade in Asia: The Commodity Futures Trading Commission designated 3 non-US formed futures and options exchanges as supposed “foreign play of trade:” Bursa Malaysia Derivatives Berhad, Singapore Exchange Derivatives Trading Limited and a Tokyo Commodity Exchange, Inc. The capitulation permits participants in a United States to entrance these markets directly by a exchanges’ electronic sequence entrance and trade relating systems.

Foreign-Domiciled IBs Authorized to Use Local Accounting Principles in Connection With CFTC Financial Filings: The Division of Swap Dealer and Intermediary Oversight of a Commodity Futures Trading Commission certified non-US domiciled introducing brokers to ask internal accounting beliefs in tie with compulsory financial filings, when internal accounting standards do not heed to generally supposed accounting beliefs adopted in a United States (US GAAP) or ubiquitous financial stating standards (IFRS) as adopted by a International Accounting Standards Board in lieu of US GAAP. Staff also certified non-US domiciled IBs to news comment balances in a internal banking where a IB is domiciled (instead of in US dollars) and not to ask unfamiliar banking collateral charges compulsory underneath CFTC regulations where a unfamiliar banking is a internal banking in a office where a IB is located. The service is theme to several conditions, including that all financial reports contingency be prepared in English.

SFC Provides Overview of HK Asset Management Industry: The Securities and Futures Commission of Hong Kong published an overview of a item government attention there. Among other findings, SFC concurred that while resources underneath government ex-Australia and ex-Japan (US $ 4.4 trillion) is tiny compared to a United States and Europe, “it has seen a fastest expansion globally in a past 5 years.” In Hong Kong, claimed SFC, there is financier direct for supports with “high-yield, multi-asset, unrestrained and choice strategies, as good as for exchange-traded products … with illiquid underlying assets” since of a low seductiveness rate environment. While outward of HK, comment products can be distributed by exchange-operated platforms, there are no such placement platforms in HK. Accordingly, “most item managers … celebrated they would find an additional placement channel to be useful, generally in a context of larger tie between a Hong Kong and Mainland China Exchanges.” Asset managers in HK explain that “the pivotal advantages of Hong Kong as a informal item government centre distortion in a plain sequence of law and augmenting connectivity to a vast financier bottom in Mainland China.”

CME Group Clarifies Proper Practices for Handling Simultaneous Buys and Sells for Different Customers: The CME Group has released an advisory notice, effective Feb 6, associated to a “proper procedures” for both open cheer and electronic markets to hoop coexisting buy and sell orders for conflicting profitable owners (these are conflicting than a mandate for pre-execution communications that are governed by CME Group Rule 539; click here to access). In general, in a open cheer market, a building attorney contingency concurrently bid and offer a prices 3 times in a demeanour that is pure to a trade pit. Afterwards, a building attorney might compare a orders in a participation of a building operations member. Where a merchant accessing an electronic height has option over dual accounts with conflicting profitable owners and seeks to enter offsetting orders, a merchant contingency initial display a buy or sell sequence for a smallest of 5 seconds, if a futures order, or 15 seconds, if an options order. Afterwards a conflicting sequence might be entered.

For some-more information, see:

Broker-Dealer Sanctioned by FINRA for Sharing Confidential Customer Information in Connection With a Class Action Lawsuit:
http://disciplinaryactions.finra.org/viewdocument.aspx?DocNB=38490

CFTC Approves Three Foreign Boards of Trade in Asia:

http://www.cftc.gov/ucm/groups/public/@otherif/documents/ifdocs/burmalderberhadregord.pdf
http://www.cftc.gov/ucm/groups/public/@otherif/documents/ifdocs/singaporeexchangderregord.pdf
http://www.cftc.gov/ucm/groups/public/@otherif/documents/ifdocs/tokyofbotregistord.pdf

CME Group Adds Its View to “Skin in a Game” Debate:
http://www.cmegroup.com/education/files/balancing-ccp-and-member-contributions-with-exposures.pdf

CME Group Amends Rule Formally to Prohibit Intraday Violations of Position Limits; Eliminates Provision Dealing With Bids and Offers:
http://www.cmegroup.com/tools-information/lookups/advisories/market-regulation/SER-7283.html

CME Group Clarifies Proper Practices for Handling Simultaneous Buys and Sells for Different Customers:
http://www.cmegroup.com/tools-information/lookups/advisories/market-regu…

FCA Fines and Bans Two Former Senior Executives of Martin Brokers for Contributing to an Unsatisfactory Corporate Culture:
http://www.fca.org.uk/static/documents/final-notices/jeremy-kraft.pdf
http://www.fca.org.uk/static/documents/final-notices/david-caplin.pdf

Foreign-Domiciled IBs Authorized to Use Local Accounting Principles in Connection With CFTC Financial Filings:
http://www.cftc.gov/ucm/groups/public/@lrlettergeneral/documents/letter/…

Futures Traders Sanctioned by CME Group Exchanges for Problematic Block Trades, ATS Breakdown, Disruptive Trading, Wash Trades and Other Violations:

Sunil Arora:
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…

Jonathan Brims
http://www.nfa.futures.org/basicnet/Case.aspx?entityid=0350282case=12-8…

Credit Suisse:
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…

Tarek El-Mdaka:
https://www.nfa.futures.org/basicnet/Case.aspx?entityid=0483896case=14-…

Stephen Gola:
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…

Michael Imperio:
https://www.nfa.futures.org/basicnet/Case.aspx?entityid=0098880case=13-…

JP Morgan Securities:

Open Position Accounting:
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…

Block Trades:
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…
http://www.cmegroup.com/tools-information/lookups/advisories/disciplinar…

Kaloti Jewellery:
https://www.nfa.futures.org/basicnet/Case.aspx?entityid=0483895case=14-9918-BCcontrib=CEI

Robert Leeds:
https://www.nfa.futures.org/basicnet/Case.aspx?entityid=0081350case=13-…
https://www.nfa.futures.org/basicnet/Case.aspx?entityid=0081350case=12-…

SEC and Two States Sanction SP for Misconduct Related to Ratings of Commercial-Backed Securities:

SEC:

SP
http://www.sec.gov/litigation/admin/2015/33-9705.pdf
http://www.sec.gov/litigation/admin/2015/33-9704.pdf
http://www.sec.gov/litigation/admin/2015/34-74103.pdf

Barbara Duka:
http://www.sec.gov/litigation/admin/2015/33-9706.pdf

See also Duka v. SEC:
https://ecf.nysd.uscourts.gov/doc1/127115443287

Massachusetts Attorney General:
http://www.mass.gov/ago/news-and-updates/press-releases/2015/2015-01-21-…

NY Attorney General:
http://www.ag.ny.gov/press-release/A.G.-Schneiderman-Settles-With-Standa…

SFC Provides Overview of HK Asset Management Industry:

http://www.sfc.hk/web/EN/files/ER/PDF/2015%20RIM%20Report%20(FINAL)_ER.pdf

Swiss Franc-Euro Decoupling Spurs Worldwide Legal and Regulatory Fallout:

CFTC Commissioner Sharon Bowen Comment:
http://www.cftc.gov/PressRoom/SpeechesTestimony/bowenstatement012115

CME Group Announcement:
http://www.cmegroup.com/tools-information/lookups/advisories/market-regu…

FCA Announcement per Alpari:
http://www.fca.org.uk/news/news-for-customers-of-alpari-uk-limited

FXCM Announcements (see statements per Swiss franc transformation and Leucadia financing):
http://ir.fxcm.com/releases.cfm

ICE Futures U.S. Announcement:
https://www.theice.com/publicdocs/futures_us/exchange_notices/ExNot01221…

NFA Announcements:
https://www.nfa.futures.org/news/newsNotice.asp?ArticleID=4531
https://www.nfa.futures.org/news/newsNotice.asp?ArticleID=4534

Swiss National Bank Announcement:
http://www.snb.ch/en/mmr/reference/pre_20150115/source/pre_20150115.en.pdf

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