U.S. COMMODITY FUTURES TRADING COMMISSION 

Three Lafayette Centre 

1155 21st Street, NW, Washington, DC 20581 

www. cftc. gov 

Office of Proceedings 

In the Matter of: 

PRO TRADING COURSE, LLC, 

Registrant. 

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CFTC Docket No. SD 12-08 

INITIAL DECISION ON DEFAULT 

Before: Philip V. McGuire, 

Judgment Officer 

Appearance: Diane M. Romaniuk, Esq., 

CFTC Division of Enforcement 

Chicago, Illinois 

Bacl{ground 

By motion filed November 28, 2012, the Commission's Division of Enforcement has 

moved for entry of a default judgment against Pro Trading Course, LLC ("PTC"), pursuant to 

Commission rules 3.60(g) and 10.93, 17 C.P.R.§§ 3.60(g) and 10.93 (2012), based on the failure 

ofPTC answer or otherwise appear or respond to the Notice of Intent to Revoke the Registration 

of Pro Trading Course, LLC ("Notice"), issued by the Commission and filed by the Division on 

September 20,2012. On September 21,2012, the Commission's Office of Proceedings served 

the Notice on PTC at the address that PTC had provided the National Futures Association for any 

communications from the Commission. 1 Thus, PIC was properly served pursuant to CFTC rule 

1 See Jung Affidavit and Certification, Exhibit 2, Division's November 28th motion. 
3.50.2 PTC defaulted by failing to respond to the Notice, and has not responded to the Division's 

motion. Accordingly, this matter is ripe for entry of a default judgment. 

As a result of its default, PTC has waived a hearing on all of the issues and is precluded 

from introducing evidence of mitigation and rehabilitation necessary to overcome the 

presumption of unfitness for registration. In addition, the allegations in the Notice, as 

supplemented by the proposed findings and conclusions in the Division's motion are deemed 

true and conclusive for purposes of finding that PTC is statutorily disqualified from registration 

under Sections 8a(2)(C) and 8a(2)(E), as amended by the Dodd-Frank Wall Street Refmm and 

Consumer Protection Act of2010, Pub. L. No. 111-203, Title VII (the Wall Street Transparency 

and Accountability Act of2010) ("Dodd-Frank Act"),§§ 701-774 (enacted July 16, 2010), 

7 U.S.C. § 12a(2)(C) and 12a(2)(E). Thus, as set out below, the Division's motion has been 

granted, PTC has been found to be statutorily disqualified from registration, and PTC's 

registration has been revoked. 

Findings of Fact 

1. Pro Trading Course, LLC ("PTC"), is a Delaware limited liability company whose 

listed address with the Commission is at 141 W. Jackson Blvd., Suite 3125, Chicago, Illinois 

60604. PTC has been registered with the Commission as a commodity trading advisor ("CTA") 

2 Pursuant to CFTC rule 3.30(a), 17 C.F.R. § 3.30(a) (20 12), the address of each registrant as submitted on its 

application for registration or as submitted on the biographical supplement shall be deemed to be the address for 

delivery to the registrant for any communications from the Commission, including any summons, complaint, notice 

and other written documents or correspondence, unless the registrant specifies another address for this purpose. 

CFTC rule 3.30(b ), 17 C.F.R. § 3.30(b) (20 12), provides that each registrant, while registered and for two years after 

the termination of registration, must notify the National Futures Association of any change of address, and that 

failure to do so may result in an order of default in any Commission or NF A proceedings. Moreover, pursuant to 

CFTC rule 3.50, 17 C.F.R. § 3.50 (20 12), for purposes of an action for the denial, suspension or revocation of 

registration, service upon a registrant will be sufficient if mailed by registered mail or certified mail return receipt 

requested properly addressed to the registrant at the address shown on his application or any amendment thereto, and 

will be complete upon mailing. 

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since February 5, 2009, pursuant to Section 4m of the Act, as amended by the Dodd- Frank Act, 

7 U.S.C. § 6m. 

2. On December 7, 2011, the Commission filed a federal civil injunctive action 

against PTC and Richard C. Regan ("Regan"), PIC's sole principal and controlling person. 

The CFTC's complaint alleged, inter alia, that from February 2009 through approximately 

September 2010, PTC, while acting as aCTA and through its controlling person, Regan, and its 

employees, directly or indirectly employed a device, scheme, or miifice to defraud clients or 

prospective clients, or engaged in transactions, practices or a course of business which operated 

as a fraud or deceit upon such persons by: one, overstating the advancement opportunity and 

profit potential of the commodity futures training program PTC was selling; and two, falsely 

representing that the trading Regan and his team conducted in Virtual Trading Room ("VTR") 

sessions was actual commodity futures trading when in fact it was only simulated trading, in 

violation of Section 4o(l)(A) and (B) of the Act, 7 U.S. C. § 6o(l)(A) and (B), and CFTC rule 

4.4l(a), 17 C.F.R § 4.41(a). CFTC v. Richard C. Regan and Pro Trading Course, LLC, Case No. 

11-CV -8679 (N.D. Ill. filed December 7, 2011).3 

3. On May 29, 2012, the Honorable Judge James B. Zagel ofthe U.S. District Court for 

the Northern District of Illinois entered an Order of Default Judgment for Permanent Injunction 

and Other Ancillary Relief against PTC and Richard C. Regan ("Default Order"). CFTC v. 

Richard C. Regan and Pro Trading Course, LLC, Case No. 11-CV-8679 (N.D. Ill. May 29, 

2012). 

Judge Zagel' s Default Order made findings of fact and conclusions of law including, 

among others, that during the relevant period, PTC, while acting as a CT A, directly or indirectly 

employed a device, scheme, or artifice to defraud clients or prospective clients, or engaged in 

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Exhibit I, Division's November 281

h motion. 

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transactions, practices or a course of business which operated as a fraud or deceit upon such 

persons. The devices, schemes, artifices, transactions, practices or courses of business included, 

but were not limited to: 

one, using false and misleading promotional material and sales 

solicitations which overstated the advancement opportunity and profit potential of 

the commodity futures training program PTC was selling, while failing to disclose 

that no PTC commodity futures trader ever advanced beyond Level 1 of the 

program or received monthly profit "payouts" approximating those depicted on its 

"Payout Charts," after completing PTC's training program; 

two, using false and misleading promotional material and sales 

solicitations in selling the VTR, which represented that the trading Regan and his 

team conducted in VTR sessions was actual commodity futures trading, while 

failing to disclose that Regan and his team conducted only simulated trading in 

their VTR sessions; and 

three, using false and misleading advertisements which represented that 

PTC was hiring commodity futures traders, while failing to disclose that PTC 

charged enrollment fees for its training program and never hired any applicant, 

after completion of its training program. 

The Default Order found that by engaging in the foregoing conduct, PTC violated Section 

4o(1)(A) and (B) ofthe Act, 7 U.S.C. § 6o(1)(A) and (B), and CFTC rule 4.4l(a), 17 C.F.R § 

4.41(a) (2012). 

4. Based on these findings, the Default Order permanently restrains, enjoins and 

prohibits PTC: one, from acting as aCTA and using the mails or any means or instrumentality 

of interstate commerce, to directly or indirectly employ a device, scheme, or artifice to defraud 

any client or prospective client, or engage in transactions, practices or a course of business which 

operate as a fraud or deceit upon such persons, in violation of Section 4o(l)(A) and (~)pfthe 

Act, 7 U.S.C. § 6o(l)(A) and (B); and two, from advetiising in a manner which employs a 

device, scheme or miifice to defraud clients or prospective clients or involves transactions, 

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practices or a course of business which operate as a fraud or deceit upon any such persons, in 

violation of Commission rule 4.41(a), 17 C.P.R. § 4.41(a) (2012). 

5. The Commission filed the Notice of Intent to Revoke the Registration of Pro Trading 

Course, LLC ("Notice") on September 20, 2012. On September 21, 2012, the Commission's 

Office of Proceedings properly served the Notice on PTC. The Notice and accompanying 

documents were served via certified mail to PTC's address listed with the Commission: 141 

West Jackson Blvd., Suite 3125, Chicago, Illinois 60604. PTC failed to respond to the Notice. 

Conclusions of Law 

Section 8a(2)(C) of the Commodity Exchange Act ("Act"), as amended by the DoddFrank Act, 7 U.S.C. § 12a(2)(C), in relevant part, authorizes the Commission to revoke the 

registration of any person "if such person is permanently ... enjoined by order, judgment, or 

decree of any court of competent jurisdiction ... including an order entered pursuant to an 

agreement of settlement to which the Commission ... is a party, from ... (ii) engaging in or 

continuing any activity when such activity involves ... fraud .... " The U.S. District Court for the 

Nmihern District of Illinois is a comi of competent jurisdiction. 

Section 8a(2)(E) of the Act, as amended by the Dodd-Frank Act, 7 U.S.C. § 12a(2)(E), in 

relevant pati, authorizes the Commission to revoke the registration of any person "if such person, 

within ten years preceding the filing of the application [for registration] or any time thereafter, 

has been found in a proceeding brought by the Commission ... (i) to have violated any provision 

of [the] Act ... where such violation involves ... fraud [or] misappropriation of funds .... " As 

noted above, the U.S. District Court for the Nmihern District of Illinois is a court of competent 

jurisdiction. 

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On May 29, 2012, the United States District Court for the Northern District of Illinois 

entered an Order of Default Judgment for Permanent Injunction and Other Ancillary Relief 

against Pro Trading Course, LLC and Richard C. Regan ("Default Order"). The Default Order 

made findings of fact and conclusions of law that PTC, while acting as a CT A, directly or 

indirectly employed a device, scheme, or artifice to defraud clients or prospective clients, or 

engaged in transactions, practices or a course of business which operated as a fraud or deceit 

upon such persons, in violation of Section 4o(l)(A) and (B) of the Act, 7 U.S.C. § 6o(l)(A) and 

(B), and Commission rule 4.41(a), 17 C.F.R § 4.41(a) (2012). As a result of these findings, the 

Default Order permanently enjoined PTC from directly or indirectly engaging in fraudulent 

conduct in violation of the Act. 

The Default Order therefore constitutes a valid basis for revoking the commodity trading 

advisor registration of Pro Trading Course, LLC, pursuant to Sections 8a(2)(C) and (E) of the 

Act, as amended. 

ORDER 

Pro Trading Course, LLC is statutorily disqualified from registration under Sections 

8a(2)(C) and (E) of the Commodity Exchange Act. Accordingly: it is concluded that Pro 

Trading Course, LLC is unfit for registration; the Division's motion for entry of a default 

judgment is hereby granted; and the registration of Pro Trading Course, LLC is hereby revoked. 

Dated December 14, 2012. 

o~ryAAJ~ Pl~i~cGuire, Judgment Officer 

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