| HOWARD KEITH MALMAN |
NFA 11BCC00041 |
NFA ID: 0193293 |
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| 0063465 | BODENSHOK, MICHELLE | 05/14/2012 | | 0193293 | MALMAN, HOWARD KEITH | 05/14/2012 | | 0371672 | OLYMPUS FUTURES INC | 05/14/2012 | | 0354706 | RUSSO, JOSHUA THOMAS JACY | 04/09/2012 |
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| 0063465 | BODENSHOK, MICHELLE | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0193293 | MALMAN, HOWARD KEITH | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0371672 | OLYMPUS FUTURES INC | • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | 0354706 | RUSSO, JOSHUA THOMAS JACY | • C.R.2-8 - FAILURE TO MAINTAIN PROCEDURES | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-2(c) - FALSE REPORTS MADE TO A CUSTOMER | | | | • C.R.2-29(a)(1) - FRAUDULENT COMM. TO PUBLIC PROHIB. | | | | • C.R.2-2(a) - CHEAT,FRAUD DECEIVE CUSTOMERS |
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| 0063465 | BODENSHOK, MICHELLE | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE | | 0193293 | MALMAN, HOWARD KEITH | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE | | 0371672 | OLYMPUS FUTURES INC | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE | | 0354706 | RUSSO, JOSHUA THOMAS JACY | • HEARING COMMITTEE | | | | • BUSINESS CONDUCT COMMITTEE |
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| 0063465 | BODENSHOK, MICHELLE | • GENERAL CONDUCT | | 0193293 | MALMAN, HOWARD KEITH | • GENERAL CONDUCT | | 0371672 | OLYMPUS FUTURES INC | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING | | 0354706 | RUSSO, JOSHUA THOMAS JACY | • SALES PRACTICE | | | | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING |
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| 0063465 | BODENSHOK, MICHELLE | • OTHER--SEE NARRATIVE | 04/27/2012 | | 0193293 | MALMAN, HOWARD KEITH | • OTHER--SEE NARRATIVE | 04/27/2012 | | | | • FINE (JOINTLY AND SEVERALLY) $100000 | 04/27/2012 | | 0371672 | OLYMPUS FUTURES INC | • OTHER--SEE NARRATIVE | 04/27/2012 | | | | • FINE (JOINTLY AND SEVERALLY) $100000 | 04/27/2012 | | 0354706 | RUSSO, JOSHUA THOMAS JACY | • PERMANENT BAR FROM NFA ASSOCIATE MEMBERSHIP | 03/22/2012 | | | | • PERMANENT BAR FROM PRINCIPAL STATUS | 03/22/2012 | | | | • PERMANENT BAR FROM NFA MEMBERSHIP | 03/22/2012 |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On December 23, 2011, NFA issued a Complaint charging Russo with deceiving commodity futures customers; making false reports to customers; exercising discretion without written authority; and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint charged OFI with failing to implement an adequate AML program. Finally, the Complaint charged OFI, Malman and Bodenshok with failing to supervise.
ANSWER:
On January 19, 2012, OFI, Malman and Bodenshok filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On April 27, 2012, pursuant to a settlement offer submitted by OFI, Malman and Bodenshok, OFI and Malman were ordered to be jointly and severally liable for the payment of a $100,000 fine. OFI and Malman were also ordered to adopt and execute specific undertakings related to: reviewing commission-to equity ratios on a firm-wide and individual account basis for compliance with NFA Requirements and taking appropriate remedial action in the event that such action is warranted; and implementing procedures to ensure that customer contacts are made in a manner that is subject to supervision by OFI. Bodenshok was ordered, for two years from the date of the Decision, not to be employed in a compliance related capacity by any NFA Member unless her compliance related duties are supervised.
Further, at NFA's request, Count III of the Complaint was dismissed. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On December 23, 2011, NFA issued a Complaint charging Russo with deceiving commodity futures customers; making false reports to customers; exercising discretion without written authority; and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint charged OFI with failing to implement an adequate AML program. Finally, the Complaint charged OFI, Malman and Bodenshok with failing to supervise.
ANSWER:
On January 19, 2012, OFI, Malman and Bodenshok filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On April 27, 2012, pursuant to a settlement offer submitted by OFI, Malman and Bodenshok, OFI and Malman were ordered to be jointly and severally liable for the payment of a $100,000 fine. OFI and Malman were also ordered to adopt and execute specific undertakings related to: reviewing commission-to equity ratios on a firm-wide and individual account basis for compliance with NFA Requirements and taking appropriate remedial action in the event that such action is warranted; and implementing procedures to ensure that customer contacts are made in a manner that is subject to supervision by OFI. Bodenshok was ordered, for two years from the date of the Decision, not to be employed in a compliance related capacity by any NFA Member unless her compliance related duties are supervised.
Further, at NFA's request, Count III of the Complaint was dismissed.
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On December 23, 2011, NFA issued a Complaint charging Russo with deceiving commodity futures customers; making false reports to customers; exercising discretion without written authority; and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint charged OFI with failing to implement an adequate AML program. Finally, the Complaint charged OFI, Malman and Bodenshok with failing to supervise.
ANSWER:
On January 19, 2012, OFI, Malman and Bodenshok filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On April 27, 2012, pursuant to a settlement offer submitted by OFI, Malman and Bodenshok, OFI and Malman were ordered to be jointly and severally liable for the payment of a $100,000 fine. OFI and Malman were also ordered to adopt and execute specific undertakings related to: reviewing commission-to equity ratios on a firm-wide and individual account basis for compliance with NFA Requirements and taking appropriate remedial action in the event that such action is warranted; and implementing procedures to ensure that customer contacts are made in a manner that is subject to supervision by OFI. Bodenshok was ordered, for two years from the date of the Decision, not to be employed in a compliance related capacity by any NFA Member unless her compliance related duties are supervised.
Further, at NFA's request, Count III of the Complaint was dismissed.
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On December 23, 2011, NFA issued a Complaint charging Russo with deceiving commodity futures customers; making false reports to customers; exercising discretion without written authority; and failing to uphold high standards of commercial honor and just and equitable principles of trade. The Complaint charged OFI with failing to implement an adequate AML program. Finally, the Complaint charged OFI, Malman and Bodenshok with failing to supervise.
ANSWER:
On January 23, 2012, Russo filed an Answer to the Complaint in which he denied the material allegations contained therein.
DECISION:
On March 22, 2012, pursuant to a settlement offer submitted by Russo, he was ordered not to apply for NFA membership, associate membership or principal status with any NFA Member at any time in the future. | | |
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