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January 12, 2015
NFA orders Orlando, Fla. firm Diamond Head Capital LLC to permanently withdraw from NFA membership and fines eFloorTrade LLC, John A. Moore and Christopher T. Moore
January 12, Chicago — National Futures Association (NFA) has ordered Diamond Head Capital LLC, an NFA Member commodity trading advisor located in Orlando, Fla., to permanently withdraw from NFA membership. NFA also fined Orlando-based NFA Member introducing broker eFloorTrade LLC, John A. Moore—the sole principal of both firms, and Christopher T. Moore—an associated person of both firms, each $15,000.
The Decision, issued by an NFA Hearing Panel, is based on a Complaint authorized by NFA's Business Conduct Committee on Dec. 31, 2013, and a settlement offer submitted by Diamond Head, eFloorTrade, and John and Christopher Moore. The Hearing Panel found that eFloorTrade and Christopher Moore engaged in unauthorized trading in an effort to avoid margin calls. The Hearing Panel also found that eFloorTrade did business with a non-Member of NFA that was required to register with the CFTC. Finally, the Hearing Panel found that eFloorTrade and John Moore failed to diligently supervise the firm's operations and employees.
The supervisory shortcomings alleged in the Complaint included a repeated failure to detect suspicious activity, a failure to implement adequate procedures to verify the identity of customers and whether customers were required to be CFTC-registered and NFA Members, and a failure to ensure that books and records were correct.