ANSWER OF RESPONDENTS - NFA Case No. 09-BCC-003 - Admitted

Sep 26, 2026

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This filing contains the respondents’ answer to a National Futures Association Business Conduct Committee complaint against Pioneer Commodities LLC and Anthony S. Bobba. The respondents admit certain procedural facts and signatures on requests for additional time for prospective associated persons to complete the Series 3 Examination, including related representations about language. They deny that such requests were not legitimate or fraudulent, and they address allegations concerning lack of investigation and compliance rule violations.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages12

Reading Time30 min

AccessFree to download

ANSWER OF RESPONDENTS

JURISDICTION

BACKGROUND

APPLICABLE RULES

COUNT 1 - VIOLATION OF NFA COMPLIANCE RULES 2-4 AND 2-9

In the Matter of: PIONEER COMMODITIES LLC(NFA ID\#363167), and ANTHONY S.BOBBA(NFA ID\#340915), Respondents. Respondents Pioneer Commodities LLC("Pioneer")and Anthony S.Bobba("Bobba"),by counsel and pursuant to the Rules of the National Futures Association("NFA"),hereby file their Answer to the NFA's Business Conduct CommitteeComplaint filed against them. ANSWER: Admitted. NATIONAL FUTURES ASSOCIATIONBEFORE THEBUSINESS CONDUCT COMMITTEE NFA Case No.09-BCC-003 # ANSWER OF RESPONDENTS JURISDICTION 1. At all times relevant to this Complaint,Pioneer was an introducing broker("IB")NFA Member located in Boca Raton,Florida.From April 2007 until October2008,Pioneer was guaranteed by Peregrine Financial Group,Inc. 2. At all times relevant to this Complaint,Bobba was the chief executive officer andan associated person("AP")of Pioneer,and an NFA Associate.Bobba also has a10%or more ownership interest in Pioneer. ANSWER: Admitted. # BACKGROUND 3. NFA received information that Pioneer and Bobba had made an unusually largenumber of requests to the testing service that administers the Series 3Examination requesting additional time for Pioneer's prospective APs tocomplete the cxam based on representations by Pioneer and Bobba that Englishwas not the primary language of these prospective APs,NFA commenced aninvestigation to determine if these requests of Pioneer and Bobba to the testingservice were legitimate and determined that many of them were not and were,infact,fraudulent in that English was,in fact,the primary language of theprospective APs for whom the requests for extra time were made. ANSWER:Pioneer and Bobba lack information sufficient to admit or deny allegationsregarding information received by NFA.Pioneer and Bobba lack information sufficientto admit or deny allegations regarding any investigation commenced and/or conductedby NFA,and/or regarding any results thereof.Pioneer and Bobba admit,oninformation and belief,that certain prospective APs of Pioneer requested additionaltime to complete the Series 3 examination because English was not their first language,and that Pioneer and/or Bobba signed off on such requests.Pioneer and Bobba deny that any requests of Pioneer and/or Bobba to the testing service were not legitimateand/or were fraudulent,and state that,at the time the requests were signed off on,Pioneer and Bobba lacked information regarding the primary language of theprospective APs other than representations made by the prospective APs toRespondents. 4. NFA's investigation also revealed that Pioneer and Bobba made absolutely noeffort to investigate their prospective APs claims that English was not theirprimary language,and simply accepted such claims at face value,withoutmaking any further inquiry.Moreover,Pioneer and Bobba prepared,signed,and submitted to the testing service,written requests for extra time whichexpressly represented that English was not the prospective APs'primarylanguage,when they knew they lacked sufficient knowledge of the facts to makesuch a representation in good faith.Pioneer and Bobba's conduct was eitherintentionally deceptive or revealed a reckless indifference on their part to theveracity of the representations they made to the testing service. ANSWER:Pioneer and Bobba lack information sufficient to admit or deny allegationsregarding the findings of NFA investigation.Pioneer and Bobba deny that they madeabsolutely no effort to investigate the claims of its prospective APs.Pioneer and Bobbaadmit that they accepted the representations of the prospective APs.Pioneer and Bobbadeny that they"prepared,signed,and submitted to the testing service,written requests for extra time which expressly represented that English was not the prospective APs'primary language,when they knew they lacked sufficient knowledge of the facts tomake such a representation in good faith." # APPLICABLE RULES 5. NFA Compliance Rule 2-4 provides that Members and Associates shal

FAQs

What case is this answer filed for?

It is filed in the matter of Pioneer Commodities LLC and Anthony S. Bobba before the National Futures Association Business Conduct Committee under NFA Case No. 09-BCC-003.

What do the respondents admit regarding the Series 3 Examination requests?

They admit signing off on certain requests to the testing service for additional time for prospective associated persons to complete the Series 3 Examination based on representations about English not being the primary language.

How do the respondents respond to the allegations that the requests were illegitimate or fraudulent?

They deny that requests to the testing service were not legitimate and/or were fraudulent, and state that at the time the requests were signed off they lacked information beyond representations made by the prospective associated persons.

Sep 26, 2026

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