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Urgent Enforcement Amended Final

NFA Bars Commodity Asset Management LLC, Fines Tulkoff $100K

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Summary

NFA has ordered Commodity Asset Management LLC, a former NFA Member commodity pool operator and commodity trading advisor in New York, not to reapply for NFA membership or act as a principal of an NFA Member at any time in the future. NFA also ordered associated person and principal Jonathan Mark Tulkoff not to reapply for nine months, pay a $100,000 fine, and comply with an undertaking if he reapplies in the future. The Hearing Panel found Tulkoff committed violations of NFA Compliance Rule 2-29 regarding non-compliant promotional material and NFA Compliance Rule 2-4 regarding standards of commercial honor.

Published by NFA on nfa.futures.org . Detected, standardized, and enriched by GovPing. Review our methodology and editorial standards .

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GovPing monitors NFA Futures News for new securities & markets regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 3 changes logged to date.

What changed

NFA issued enforcement orders against Commodity Asset Management LLC and Jonathan Mark Tulkoff for violations of NFA Compliance Rule 2-29 (non-compliant promotional material) and NFA Compliance Rule 2-4 (contrary to high standards of commercial honor and just and equitable principles of trade). Commodity Asset Management LLC was ordered permanently barred from NFA membership and prohibited from acting as a principal of any NFA Member. Tulkoff received a nine-month bar, $100,000 fine, and a compliance undertaking for any future reapplication.\n\nCommodity pool operators and commodity trading advisors registered with NFA should review their promotional materials for compliance with NFA Compliance Rule 2-29 requirements and ensure all marketing communications meet the standards required under NFA rules.

Penalties

$100,000 fine against Jonathan Mark Tulkoff

Archived snapshot

Apr 25, 2026

GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.

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For more information contact:

Christie von Ohlen, 312-781-1497, cvonohlen@nfa.futures.org
Joseph McCarthy, 312-781-1357, jmccarthy@nfa.futures.org

NFA orders former New York-based commodity pool operator and commodity trading advisor Commodity Asset Management LLC not to reapply for NFA membership

March 9, Chicago – NFA has ordered Commodity Asset Management LLC (Commodity Asset Management), a former NFA Member commodity pool operator and commodity trading advisor located in New York, N.Y., not to reapply for NFA membership or act as a principal of an NFA Member at any time in the future. NFA also ordered Jonathan Mark Tulkoff, a prior associated person and principal of Commodity Asset Management and former NFA Associate, not to reapply for NFA membership or act as a principal of an NFA Member for nine months and further ordeed him to pay a $100,000 fine and comply with an undertaking if he reapplies for NFA membership or principal status in the future.

The Decision, issued by an NFA Hearing Panel, is based on a Complaint issued by NFA's Business Conduct Committee (BCC) and a settlement offer submitted by Commodity Asset Management and Tulkoff, in which they neither admitted nor denied the allegations in the Complaint. In the Complaint, the BCC alleged, among other things, that Commodity Asset Management and Tulkoff used promotional material that did not comply with NFA requirements, in violation of NFA Compliance Rule 2-29, and acted contrary to high standards of commercial honor and just and equitable principles of trade, in violation of NFA Compliance Rule 2-4. In its Decision, the Hearing Panel found that Tulkoff committed the violations alleged against him in the Complaint.

The complete text of the Complaint and Decision can be viewed on NFA's website.

Named provisions

NFA Compliance Rule 2-29 NFA Compliance Rule 2-4

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Last updated

Classification

Agency
NFA
Filed
March 9th, 2026
Instrument
Enforcement
Branch
SRO
Legal weight
Binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Financial advisers Investors Fund managers
Industry sector
5231 Securities & Investments
Activity scope
Commodity pool operation Trading advisory Promotional material compliance
Geographic scope
United States US

Taxonomy

Primary area
Commodities & Derivatives
Operational domain
Compliance
Topics
Securities Consumer Protection

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