| FXDIRECTDEALER LLC |
NFA 12BCC00021 |
NFA ID: 0397435 |
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| 0397435 | FXDIRECTDEALER LLC | | | 0209125 | GREEN, JAMES EMERSON | |
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| 0397435 | FXDIRECTDEALER LLC | • C.R.2-36 - FOREX ANTI-FRAUD RULE | | | | • C.R.2-43(a) - FOREX PRICE ADJUSTMENTS | | | | • C.R.2-10 - RECORDKEEPING FCMS/IBS | | | | • C.R.2-36(b)(5) - FDMs NOT SUBMIT FALSE OR MISLEADING INFORMATION TO NFA | | | | • C.R.2-9(c) - ANTI-MONEY LAUNDERING PROGRAM | | | | • C.R.2-36(d) - FOREX DEALER MEMBERS DOING BUSINESS WITH NON-MEMBERS | | | | • C.R.2-36(b)(4) - ENGAGE IN ACTS REGARDING PRICE OF ANY FOREIGN CURRENCY OR FOREX TRANSACTION | | | | • C.R.2-36(c) - FOREX DEALER MEMBERS OBSERVE HIGH STDS OF COMMERCIAL HONOR | | | | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES | | | | • C.R.2-36(b)(1) - CHEAT, DEFRAUD, DECEIVE FOREX CUSTOMERS | | 0209125 | GREEN, JAMES EMERSON | • C.R.2-36(b)(1) - CHEAT, DEFRAUD, DECEIVE FOREX CUSTOMERS | | | | • C.R.2-36(c) - FOREX DEALER MEMBERS OBSERVE HIGH STDS OF COMMERCIAL HONOR | | | | • C.R.2-36(b)(5) - FDMs NOT SUBMIT FALSE OR MISLEADING INFORMATION TO NFA | | | | • C.R.2-36(e) - FOREX DEALER MEMBERS SUPERVISION OF EMPLOYEES |
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| 0397435 | FXDIRECTDEALER LLC | • BUSINESS CONDUCT COMMITTEE | | 0209125 | GREEN, JAMES EMERSON | • BUSINESS CONDUCT COMMITTEE |
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| 0397435 | FXDIRECTDEALER LLC | • GENERAL CONDUCT | | | | • OFFICE RECORDKEEPING | | 0209125 | GREEN, JAMES EMERSON | • GENERAL CONDUCT |
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| | | No penalties have been selected for this case. |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On June 29, 2012, NFA issued a Complaint charging FXDD with using asymmetrical price slippage settings that favored FXDD over customers; failing to supervise the trade integrity of the firm's electronic trading systems; failing to maintain complete and accurate records; failing to review the use of promotional material; making improper price adjustments in customers' accounts; knowingly converting customer funds; failing to implement an adequate AML program; and failing to develop and implement adequate procedures to ensure that all entities and persons that the firm does business with are registered with the CFTC and NFA Members. The Complaint also charged FXDD and Green with willfully submitting misleading information to NFA and others; failing to treat all customers equally when giving price adjustments; and failing to supervise.
ANSWER:
On October 1, 2012, FXDD filed an Answer to the Complaint in which the firm denied the material allegations contained therein.
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On June 29, 2012, NFA issued a Complaint charging FXDD with using asymmetrical price slippage settings that favored FXDD over customers; failing to supervise the trade integrity of the firm's electronic trading systems; failing to maintain complete and accurate records; failing to review the use of promotional material; making improper price adjustments in customers' accounts; knowingly converting customer funds; failing to implement an adequate AML program; and failing to develop and implement adequate procedures to ensure that all entities and persons that the firm does business with are registered with the CFTC and NFA Members. The Complaint also charged FXDD and Green with willfully submitting misleading information to NFA and others; failing to treat all customers equally when giving price adjustments; and failing to supervise.
ANSWER:
On October 1, 2012, Green filed an Answer to the Complaint in which he denied the material allegations contained therein.
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