The US National Futures Association (NFA) has ordered Turing FX LLC and Rockhill Capital Management LLC, NFA Member commodity pool operators located in Chicago, Ill., not to reapply for NFA membership or act as a principal of an NFA Member at any time in the future.

NFA has also ordered Christian Hillenbrand, the sole principal and associated person of both Turing and Rockhill, to withdraw from, and not reapply for, NFA membership status for seven years and to comply with other requirements and undertakings, including paying a $150,000 fine if he seeks to reapply for NFA membership in the future.

The Decision, issued by NFA’s Business Conduct Committee (BCC), is based on a Complaint issued by the BCC and a settlement offer submitted by Turing, Rockhill and Hillenbrand, in which they neither admitted nor denied the allegations in the Complaint.

The Complaint alleged that, among other things, Turing and Rockhill permitted the pools they operated to make improper advances of pool assets to Turing and Rockhill and failed to deliver NFA-accepted Disclosure Documents to participants in the pools they operated prior to accepting participants’ subscriptions.

The Complaint also alleged that Turing, Rockhill and Hillenbrand failed to observe high standards of commercial honor and just and equitable principles of trade regarding their use of the pools’ assets.

Further, the Complaint alleged that Rockhill and Hillenbrand provided NFA and the participants in the pool operated by Rockhill with false and misleading information as to the pool’s net asset value.

In its Decision, the BCC found that Turing, Rockhill and Hillenbrand violated NFA Compliance Rule 2-4, that Turing and Rockhill violated NFA Compliance Rules 2-45 and 2-13, and that Rockhill and Hillenbrand violated NFA Compliance Rule 2-2(f).