NFA - National Futures Association

03/09/2026 | Press release | Distributed by Public on 03/09/2026 13:28

DECISION IN DISCIPLINARY CASES (Commodity Asset Management LLC and Jonathan Mark Tulkoff)

Case Documents:

Amended Answer Amended Complaint Amended Decision Amended Notice Of Intent Amended Notice Of Member Responsibility Action Answer Appeals Committee Decision Cftc Decision Cftc Order Circuit Court Appeal Complaint Decision Federal Court Order Final Order Interim Order Nfa Reply Notice Notice And Order Lifting Member Responsibility Action Notice And Order Lifting Suspension Of Membership Notice And Order Of Suspension Notice Of Appeal Notice Of Associate Responsibility Action Notice Of Intent Notice Of Member Responsibility Action Notice Of Suspension Of Membership Notice Of Termination Of Ara Notice Of Termination Of Member Responsibility Action Order Order Denying Petition Order Lifting Conditions Order Of Dismissal Petition To Stay Response To Amended Notice Of Intent Response To Notice Of Intent Withdrawal Of Notice Of Intent

Narrative Summary:

COMPLAINT:

On October 22, 2025, NFA's Business Conduct Committee (BCC) issued a Complaint against Commodity Asset Management LLC (Commodity Ass... et Management) and Jonathan Mark Tulkoff (Tulkoff), charging them with using misleading promotional material and acting contrary to high standards of commercial honor and just and equitable principles of trade. The Complaint also charges Commodity Asset Management with failing to disclose adequate information in audited pool financial statements.

ANSWER TO COMPLAINT:

On December 22, 2025, Commodity Asset Management and Tulkoff filed an Answer to the Complaint.


DECISION:

On March 9, 2026, NFA's Hearing Panel issued a Decision, pursuant to Commodity Asset Management and Tulkoff's settlement offer, and ordered Commodity Asset Management not to reapply for NFA membership or act as a principal of an NFA Member at any time in the future. The Hearing Panel ordered Tulkoff not to apply for NFA membership, or reapply for NFA associate membership, or be listed or act as a principal of an NFA Member for nine months. The Hearing Panel further ordered Tulkoff to pay a $100,000 fine, if he applies for NFA membership, reapplies for NFA associate membership, or seeks principal status after the expiration of the nine-month period, and restricted his supervisory activities for one year, commencing immediately following the expiration of the nine-month period.
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Rule Type:

  • C.R.2-13 - RECORDKEEPING FOR CPOS/CTAS
  • C.R.2-4 - HIGH STDS. OF COMMERCIAL HONOR
  • C.R.2-29(b) - CONTENT OF PROMOTIONAL MATERIAL

Committee:

  • Business Conduct Committee
  • Hearing Committee

Action Type(s):

  • GENERAL CONDUCT
  • SALES PRACTICE

Penalty/Event:

  • ORDERED NOT TO REAPPLY FOR NFA MEMBERSHIP
  • ORDERED NOT TO ACT AS PRINCIPAL OF AN NFA MEMBER
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