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Case Summary

CASTLE TRADING INC NFA 06BCC00007 NFA ID: 0302967

Respondent/Effective Date Summary
 NFA IDRespondentEffective Date
 0302967CASTLE TRADING INC01/31/2007
 0322968CHP ASSET MANAGEMENT LLC01/31/2007
 0296807PLYAM, YURI01/31/2007
Rule Summary
 NFA IDRespondentRule Type
 0302967CASTLE TRADING INC• C.R.2-5 - FAILURE TO COOPERATE W/ NFA
  • F.R.SEC5NEW - INTRODUCING BROKER FINANCIAL REQUIREMENTS
  • C.R.2-9(a) - SUPERVISION OF EMPLOYEES
  • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM
  • C.R.2-10 - RECORDKEEPING FCMS/IBS
 0322968CHP ASSET MANAGEMENT LLC• C.R.2-13 - RECORDKEEPING FOR CPOS/CTAS
  • C.R.2-9(a) - SUPERVISION OF EMPLOYEES
  • C.R.2-5 - FAILURE TO COOPERATE W/ NFA
 0296807PLYAM, YURI• C.R.2-9(a) - SUPERVISION OF EMPLOYEES
  • C.R.2-5 - FAILURE TO COOPERATE W/ NFA
Committee Summary
 NFA IDRespondentCommittee
 0302967CASTLE TRADING INC• BUSINESS CONDUCT COMMITTEE
  • HEARING COMMITTEE
 0322968CHP ASSET MANAGEMENT LLC• HEARING COMMITTEE
  • BUSINESS CONDUCT COMMITTEE
 0296807PLYAM, YURI• HEARING COMMITTEE
  • BUSINESS CONDUCT COMMITTEE
Action Summary
 NFA IDRespondentAction Types
 0302967CASTLE TRADING INC• GENERAL CONDUCT
  • OFFICE RECORDKEEPING
  • FINANCIAL
 0322968CHP ASSET MANAGEMENT LLC• GENERAL CONDUCT
 0296807PLYAM, YURI• GENERAL CONDUCT
Penalty/Event Summary
 NFA IDRespondentPenalty/EventEvent Date
 0302967CASTLE TRADING INC• SUBMIT PROMOTIONAL MATERIAL TO NFA INDF01/16/2007
  • OTHER--SEE NARRATIVE01/16/2007
 0322968CHP ASSET MANAGEMENT LLC• FINE $3000001/16/2007
  • PERMANENT WITHDRAWAL FROM NFA MEMBERSHIP01/16/2007
 0296807PLYAM, YURI• OTHER--SEE NARRATIVE01/16/2007
Narrative Summary
Narrative for 0302967 - CASTLE TRADING INC
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**

COMPLAINT -

On April 13, 2006, NFA issued a Complaint charging Plyam, Castle and CHP with failure to comply with Decisions issued by the BCC and failure to supervise. The Complaint also charged Castle with failure to maintain required books and records, failure to file required telegraphic notice and failure to initiate an adequate anti-money laundering program. Finally, the Complaint charged CHP with failure to prepare accurate pool statements.

ANSWER -

On May 17, 2006, Castle, CHP and Plyam filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On January 16, 2007, CHP and Acceleration were ordered to terminate their NFA memberships and neither CHP nor Acceleration shall apply for NFA membership at any time in the future. CHP was also ordered to pay a $30,000 fine. It was ordered that neither Plyam nor any firm of which he is a principal or which he otherise controls shall operate any commodity pool for three years. Castle was ordered to submit all promotional material to NFA for review and approval prior to first use and maintain minimum ANC of at least $100,000 for eighteen months. The Decision also granted NFA's Motion to dismiss the allegation in the Complaint that Plyam, Castle and CHP failed to comply with Decisions issued by the BCC.

 
Narrative for 0322968 - CHP ASSET MANAGEMENT LLC
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**

COMPLAINT -

On April 13, 2006, NFA issued a Complaint charging Plyam, Castle and CHP with failure to comply with Decisions issued by the BCC and failure to supervise. The Complaint also charged Castle with failure to maintain required books and records, failure to file required telegraphic notice and failure to initiate an adequate anti-money laundering program. Finally, the Complaint charged CHP with failure to prepare accurate pool statements.

ANSWER -

On May 17, 2006, Castle, CHP and Plyam filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On January 16, 2007, CHP and Acceleration were ordered to terminate their NFA memberships and neither CHP nor Acceleration shall apply for NFA membership at any time in the future. CHP was also ordered to pay a $30,000 fine. It was ordered that neither Plyam nor any firm of which he is a principal or which he otherise controls shall operate any commodity pool for three years. Castle was ordered to submit all promotional material to NFA for review and approval prior to first use and maintain minimum ANC of at least $100,000 for eighteen months. The Decision also granted NFA's Motion to dismiss the allegation in the Complaint that Plyam, Castle and CHP failed to comply with Decisions issued by the BCC.

 
Narrative for 0296807 - PLYAM, YURI
**TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS. FOR A COPY OF DOCUMENTS, CONTACT NFA'S INFORMATION CENTER.**

COMPLAINT -

On April 13, 2006, NFA issued a Complaint charging Plyam, Castle and CHP with failure to comply with Decisions issued by the BCC and failure to supervise. The Complaint also charged Castle with failure to maintain required books and records, failure to file required telegraphic notice and failure to initiate an adequate anti-money laundering program. Finally, the Complaint charged CHP with failure to prepare accurate pool statements.

ANSWER -

On May 17, 2006, Castle, CHP and Plyam filed an Answer to the Complaint in which they denied the material allegations contained therein.

DECISION -

On January 16, 2007, CHP and Acceleration were ordered to terminate their NFA memberships and neither CHP nor Acceleration shall apply for NFA membership at any time in the future. CHP was also ordered to pay a $30,000 fine. It was ordered that neither Plyam nor any firm of which he is a principal or which he otherise controls shall operate any commodity pool for three years. Castle was ordered to submit all promotional material to NFA for review and approval prior to first use and maintain minimum ANC of at least $100,000 for eighteen months. The Decision also granted NFA's Motion to dismiss the allegation in the Complaint that Plyam, Castle and CHP failed to comply with Decisions issued by the BCC.

 
Case Documents Summary
 NFA IDRespondentDocument Type
 0302967CASTLE TRADING INCANSWER
 0302967CASTLE TRADING INCCOMPLAINT
 0302967CASTLE TRADING INCDECISION
 0322968CHP ASSET MANAGEMENT LLCANSWER
 0322968CHP ASSET MANAGEMENT LLCCOMPLAINT
 0322968CHP ASSET MANAGEMENT LLCDECISION
 0296807PLYAM, YURIANSWER
 0296807PLYAM, YURICOMPLAINT
 0296807PLYAM, YURIDECISION
 
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