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Case Summary

LEVEL III MANAGEMENT LLC NFA 12MRA00005 NFA ID: 0384343

Respondent/Effective Date Summary
 NFA IDRespondentEffective Date
 0190801GWYN, BRUCE ALEXANDER06/12/2012
 0384343LEVEL III MANAGEMENT LLC06/12/2012
 0382256LEVEL III TRADING LLC06/12/2012
Rule Summary
No rules have been selected for this case.
Committee Summary
 NFA IDRespondentCommittee
 0190801GWYN, BRUCE ALEXANDER• EXECUTIVE COMMITTEE
 0384343LEVEL III MANAGEMENT LLC• EXECUTIVE COMMITTEE
 0382256LEVEL III TRADING LLC• EXECUTIVE COMMITTEE
Action Summary
 NFA IDRespondentAction Types
 0190801GWYN, BRUCE ALEXANDER• NFA GENERAL DISCIPLINARY ACTION
 0384343LEVEL III MANAGEMENT LLC• NFA GENERAL DISCIPLINARY ACTION
 0382256LEVEL III TRADING LLC• NFA GENERAL DISCIPLINARY ACTION
Penalty/Event Summary
 NFA IDRespondentPenalty/EventEvent Date
 0190801GWYN, BRUCE ALEXANDER• MEMBER RESPONSIBILITY ACTION06/12/2012
  • SUSPENDED FROM MEMBERSHIP INDF06/12/2012
 0384343LEVEL III MANAGEMENT LLC• SUSPENDED FROM MEMBERSHIP INDF06/12/2012
  • MEMBER RESPONSIBILITY ACTION06/12/2012
 0382256LEVEL III TRADING LLC• MEMBER RESPONSIBILITY ACTION06/12/2012
  • SUSPENDED FROM MEMBERSHIP INDF06/12/2012
Narrative Summary
Narrative for 0190801 - GWYN, BRUCE ALEXANDER
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION:

On June 12, 2012, NFA issued a Member Responsibility Action ("MRA") against Level III Management LLC ("L3M") and Level III Trading LLC ("L3T")and an Associate Responsibility Action ("ARA") against Bruce A. Gwyn ("Gwyn") whereby:

1. L3M, L3T and Gwyn are suspended from NFA membership and associate membership, respectively, effective immediately and until further notice;

2. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from soliciting or accepting any funds from customers, pool participants or investors, soliciting investments for any managed accounts, pools or other investment vehicles, including the Level III Trading Partners LP ("L3LP" or "the Fund"); or placing any trades, except liquidation trades in L3LP or any other customer account or fund over which L3M, L3T and Gwyn exercise control;

3. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from disbursing or transferring any funds over which they or any person acting on their behalf exercises control (including bank, trading and other types of accounts), without prior approval from NFA; and

4. L3M, L3T and Gwyn are required to provide copies of this MRA/ARA by overnight courier or e-mail to all: a) customers; b) participants in L3LP; c) other investors; and d) banks, brokerage firms, and other financial institutions with which money, securities or other property is on deposit in the name of L3M, L3T, L3LP, or Gwyn or over which L3M, L3T, L3LP or Gwyn exercise control.

This action is effective immediately and deemed necessary to protect customers of L3M and L3T since L3M and Gwyn have misappropriated L3LP's funds and misled customers regarding the value of their investments in L3LP by providing customers with false and misleading performance information about those investments. Moreover, L3M and Gwyn appear to have acted in a manner that placed Gwyn's interests above the interests of his customers by knowingly investing the pool participants' assets in several investment ventures without adequately disclosing the investments' risky nature and Gwyn's relationship to them. In addition, L3M and Gwyn have not provided certain L3M customers with a current disclosure document ("DD") approved by NFA that adequately discusses the true nature of the Fund's investments. Lastly, L3M and Gwyn have failed to cooperate with NFA's investigation because they have refused to make Gwyn available in person to answer NFA's questions about L3M's and L3T's activities, and Gwyn and L3M have failed to produce requested records regarding the Fund's riskiest investments (i.e., all supporting documents for the Fund's asset balances).

The MRA and ARA will remain in effect until such time as L3M, L3T and Gwyn have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements.

 
Narrative for 0384343 - LEVEL III MANAGEMENT LLC
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION:

On June 12, 2012, NFA issued a Member Responsibility Action ("MRA") against Level III Management LLC ("L3M") and Level III Trading LLC ("L3T")and an Associate Responsibility Action ("ARA") against Bruce A. Gwyn ("Gwyn") whereby:

1. L3M, L3T and Gwyn are suspended from NFA membership and associate membership, respectively, effective immediately and until further notice;

2. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from soliciting or accepting any funds from customers, pool participants or investors, soliciting investments for any managed accounts, pools or other investment vehicles, including the Level III Trading Partners LP ("L3LP" or "the Fund"); or placing any trades, except liquidation trades in L3LP or any other customer account or fund over which L3M, L3T and Gwyn exercise control;

3. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from disbursing or transferring any funds over which they or any person acting on their behalf exercises control (including bank, trading and other types of accounts), without prior approval from NFA; and

4. L3M, L3T and Gwyn are required to provide copies of this MRA/ARA by overnight courier or e-mail to all: a) customers; b) participants in L3LP; c) other investors; and d) banks, brokerage firms, and other financial institutions with which money, securities or other property is on deposit in the name of L3M, L3T, L3LP, or Gwyn or over which L3M, L3T, L3LP or Gwyn exercise control.

This action is effective immediately and deemed necessary to protect customers of L3M and L3T since L3M and Gwyn have misappropriated L3LP's funds and misled customers regarding the value of their investments in L3LP by providing customers with false and misleading performance information about those investments. Moreover, L3M and Gwyn appear to have acted in a manner that placed Gwyn's interests above the interests of his customers by knowingly investing the pool participants' assets in several investment ventures without adequately disclosing the investments' risky nature and Gwyn's relationship to them. In addition, L3M and Gwyn have not provided certain L3M customers with a current disclosure document ("DD") approved by NFA that adequately discusses the true nature of the Fund's investments. Lastly, L3M and Gwyn have failed to cooperate with NFA's investigation because they have refused to make Gwyn available in person to answer NFA's questions about L3M's and L3T's activities, and Gwyn and L3M have failed to produce requested records regarding the Fund's riskiest investments (i.e., all supporting documents for the Fund's asset balances).

The MRA and ARA will remain in effect until such time as L3M, L3T and Gwyn have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements.

 
Narrative for 0382256 - LEVEL III TRADING LLC
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**

NOTICE OF MEMBER RESPONSIBILITY ACTION AND ASSOCIATE RESPONSIBILITY ACTION:

On June 12, 2012, NFA issued a Member Responsibility Action ("MRA") against Level III Management LLC ("L3M") and Level III Trading LLC ("L3T")and an Associate Responsibility Action ("ARA") against Bruce A. Gwyn ("Gwyn") whereby:

1. L3M, L3T and Gwyn are suspended from NFA membership and associate membership, respectively, effective immediately and until further notice;

2. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from soliciting or accepting any funds from customers, pool participants or investors, soliciting investments for any managed accounts, pools or other investment vehicles, including the Level III Trading Partners LP ("L3LP" or "the Fund"); or placing any trades, except liquidation trades in L3LP or any other customer account or fund over which L3M, L3T and Gwyn exercise control;

3. L3M, L3T and Gwyn, and any person acting on behalf of L3M and L3T, are prohibited from disbursing or transferring any funds over which they or any person acting on their behalf exercises control (including bank, trading and other types of accounts), without prior approval from NFA; and

4. L3M, L3T and Gwyn are required to provide copies of this MRA/ARA by overnight courier or e-mail to all: a) customers; b) participants in L3LP; c) other investors; and d) banks, brokerage firms, and other financial institutions with which money, securities or other property is on deposit in the name of L3M, L3T, L3LP, or Gwyn or over which L3M, L3T, L3LP or Gwyn exercise control.

This action is effective immediately and deemed necessary to protect customers of L3M and L3T since L3M and Gwyn have misappropriated L3LP's funds and misled customers regarding the value of their investments in L3LP by providing customers with false and misleading performance information about those investments. Moreover, L3M and Gwyn appear to have acted in a manner that placed Gwyn's interests above the interests of his customers by knowingly investing the pool participants' assets in several investment ventures without adequately disclosing the investments' risky nature and Gwyn's relationship to them. In addition, L3M and Gwyn have not provided certain L3M customers with a current disclosure document ("DD") approved by NFA that adequately discusses the true nature of the Fund's investments. Lastly, L3M and Gwyn have failed to cooperate with NFA's investigation because they have refused to make Gwyn available in person to answer NFA's questions about L3M's and L3T's activities, and Gwyn and L3M have failed to produce requested records regarding the Fund's riskiest investments (i.e., all supporting documents for the Fund's asset balances).

The MRA and ARA will remain in effect until such time as L3M, L3T and Gwyn have demonstrated to the satisfaction of NFA that they are in complete compliance with all NFA Requirements.

 
Case Documents Summary
 NFA IDRespondentDocument Type
 0190801GWYN, BRUCE ALEXANDERNOTICE OF MEMBER RESPONSIBILITY ACTION
 0384343LEVEL III MANAGEMENT LLCNOTICE OF MEMBER RESPONSIBILITY ACTION
 0382256LEVEL III TRADING LLCNOTICE OF MEMBER RESPONSIBILITY ACTION
 
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