Abstract:The National Futures Association (NFA) has permanently barred Commodity Asset Management LLC, a former NFA Member commodity pool operator (CPO) and commodity trading advisor (CTA) based in New York, from reapplying for NFA membership or acting as a principal of an NFA Member in the future.

The National Futures Association (NFA) has permanently barred Commodity Asset Management LLC, a former NFA Member commodity pool operator (CPO) and commodity trading advisor (CTA) based in New York, from reapplying for NFA membership or acting as a principal of an NFA Member in the future.
The regulator also sanctioned Jonathan Mark Tulkoff, a former associated person and principal of Commodity Asset Management and a former NFA Associate.
Under the order, Tulkoff is prohibited from reapplying for NFA membership or acting as a principal of an NFA Member for a period of nine months. In addition, he must pay a $100,000 fine and comply with certain undertakings should he seek to reapply for NFA membership or principal status in the future.
Decision Issued Following Settlement
The sanctions were imposed in a Decision issued by an NFA Hearing Panel, following a Complaint filed by NFAs Business Conduct Committee (BCC).
The decision was based on a settlement offer submitted by Commodity Asset Management and Tulkoff. As part of the settlement, both respondents neither admitted nor denied the allegations outlined in the Complaint.
Allegations of Non-Compliant Promotional Materials
According to the Complaint, the BCC alleged that Commodity Asset Management and Tulkoff used promotional materials that failed to comply with NFA regulations, violating NFA Compliance Rule 2-29, which governs communications with the public and promotional material.
The regulator further alleged that the respondents failed to uphold high standards of commercial honor and just and equitable principles of trade, constituting a violation of NFA Compliance Rule 2-4.
As a result, the panel approved the settlement and imposed the disciplinary sanctions against both the firm and its former principal.
The NFA‘s enforcement action underscores the regulator’s ongoing focus on ensuring that market participants maintain accurate promotional practices and adhere to ethical standards in their communications with investors.
