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On November 16, 2012, NFA issued a Complaint charging Dank with failing to supervise.
Dank was ordered to pay a $7,500 fine. In addition, Dank may only operate Champion as a GIB for three years. If, during the three-year period, Dank withdraws or otherwise terminates his association with Champion and becomes registered as an AP of another NFA Member firm, he may only be a principal of that firm if he is not a financial principal and performs no function relating to financial matters for the firm. Moreover, if the firm is an IB, Dank may not even serve as a non-financial principal unless the firm operates as a GIB. During the three-year period, Champion - and any other NFA Member of which Dank is a non-financial principal - shall employ no more than four APs, excluding Dank, and these APs cannot have previously worked at a "Disciplined Firm," as that term is defined in the Interpretive Notice to NFA Compliance Rule 2-9 entitled "Enhanced Supervisory Requirements."