| STONEHENGE ASSET MANAGEMENT LLC |
NFA 12BCC00029 |
NFA ID: 0411098 |
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| 0212526 | MICHAEL, STEVEN ALAN | 05/30/2013 | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | 05/30/2013 |
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| 0212526 | MICHAEL, STEVEN ALAN | • C.R.2-29(b)(1) - USE OF DECEPTIVE PROMO MATER. | | | | • C.R.2-13 - RECORDKEEPING FOR CPOS/CTAS | | | | • C.R.2-5 - FAILURE TO COOPERATE W/ NFA | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-2(f) - FALSE INFORMATION TO NFA/AGENTS | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES | | | | • C.R.2-29(b)(2) - MISSTATEMT/OMISSION OF FACT PROMP | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | • C.R.2-29(b)(1) - USE OF DECEPTIVE PROMO MATER. | | | | • C.R.2-46 - CPO QUARTERLY REPORTING REQUIREMENTS | | | | • C.R.2-29(b)(2) - MISSTATEMT/OMISSION OF FACT PROMP | | | | • C.R.2-13 - RECORDKEEPING FOR CPOS/CTAS | | | | • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR | | | | • C.R.2-2(f) - FALSE INFORMATION TO NFA/AGENTS | | | | • C.R.2-45 - PROHIBITION OF LOANS BY COMMODITY POOLS TO CPOS AND AFFILIATED ENTITIES | | | | • C.R.2-9(a) - SUPERVISION OF EMPLOYEES |
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| 0212526 | MICHAEL, STEVEN ALAN | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | • BUSINESS CONDUCT COMMITTEE | | | | • HEARING COMMITTEE |
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| 0212526 | MICHAEL, STEVEN ALAN | • GENERAL CONDUCT | | | | • SALES PRACTICE | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | • GENERAL CONDUCT | | | | • SALES PRACTICE |
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| 0212526 | MICHAEL, STEVEN ALAN | • FINE (JOINTLY AND SEVERALLY) $50000 | 05/15/2013 | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | • OTHER--SEE NARRATIVE | 05/15/2013 | | | | • FINE (JOINTLY AND SEVERALLY) $50000 | 05/15/2013 |
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| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On October 15, 2012, NFA issued a Complaint charging Stonehenge and Michael with submitting misleading information to NFA about the status of the SD3 pool; failing to observe high standards of commercial honor and just and equitable principles of trade; using inflated figures in its promotional material; aggregating the funds of SD1's different investment classes together in the SDMaster trading accounts thereby making the equity of participants in investment classes with higher funding levels available to margin the positions of participants in investment classes with lower funding levels; misallocating pool funds to pay Stonehenge and Michael's expenses; making untimely reimbursements and redemptions; using misleading offering memorandum for SD1; and failing to supervise the overall operations of the firm. The Complaint charged Stonehenge with failing to obtain acknowledgements confirming that investors met the definition of a QEP; failing to provide a disclosure document to individuals it solicited to invest in the SD3 pool; submitting inaccurate PQRs; failing to prepare SD1 account statements in accordance with U.S. Generally Accepted Accounting Principles; and allowing SD1 to make a loan to Stonehenge. Michael is charged with failing to abide by the terms of the settlement and Decision in a 2010 BCC case.
ANSWER:
On January 2, 2013, Stonehenge and Michael filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On May 15, 2013, pursuant to a settlement offer submitted by Stonehenge and Michael, Stonehenge was ordered to engage an independent third-party administrator to provide full administrative services to any pool operated by Stonehenge, including, but not limited to, effecting redemptions and ensuring that expenses paid by any such pools are properly authorized and disclosed to participants. Also, Stonehenge and Michael are jointly and severally liable for the payment of $50,000 to NFA. | | | |
| **TO VIEW DOCUMENTS, GO TO CASE DOCUMENTS.**
COMPLAINT:
On October 15, 2012, NFA issued a Complaint charging Stonehenge and Michael with submitting misleading information to NFA about the status of the SD3 pool; failing to observe high standards of commercial honor and just and equitable principles of trade; using inflated figures in its promotional material; aggregating the funds of SD1's different investment classes together in the SDMaster trading accounts thereby making the equity of participants in investment classes with higher funding levels available to margin the positions of participants in investment classes with lower funding levels; misallocating pool funds to pay Stonehenge and Michael's expenses; making untimely reimbursements and redemptions; using misleading offering memorandum for SD1; and failing to supervise the overall operations of the firm. The Complaint charged Stonehenge with failing to obtain acknowledgements confirming that investors met the definition of a QEP; failing to provide a disclosure document to individuals it solicited to invest in the SD3 pool; submitting inaccurate PQRs; failing to prepare SD1 account statements in accordance with U.S. Generally Accepted Accounting Principles; and allowing SD1 to make a loan to Stonehenge. Michael is charged with failing to abide by the terms of the settlement and Decision in a 2010 BCC case.
ANSWER:
On January 2, 2013, Stonehenge and Michael filed an Answer to the Complaint in which they denied the material allegations contained therein.
DECISION:
On May 15, 2013, pursuant to a settlement offer submitted by Stonehenge and Michael, Stonehenge was ordered to engage an independent third-party administrator to provide full administrative services to any pool operated by Stonehenge, including, but not limited to, effecting redemptions and ensuring that expenses paid by any such pools are properly authorized and disclosed to participants. Also, Stonehenge and Michael are jointly and severally liable for the payment of $50,000 to NFA. | | |
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| 0212526 | MICHAEL, STEVEN ALAN | ANSWER | | 0212526 | MICHAEL, STEVEN ALAN | COMPLAINT | | 0212526 | MICHAEL, STEVEN ALAN | DECISION | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | ANSWER | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | COMPLAINT | | 0411098 | STONEHENGE ASSET MANAGEMENT LLC | DECISION |
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