UNITED STATES OF AMERICA 

Before the 

COMMODITY FUTURES TRADING COMMISSION 

MICHAEL E. ROSE 

v. CFTC Docket No. CRAA-12-04 

NATIONAL FUTURES ASSOCIATION 

and 

MARTIN BEDICK 

v. CFTC Docket No. CRAA-12-05 

NATIONAL FUTURES ASSOCIATION 

ORDER OF SUMMARY AFFIRMANCE 

Our review of the record and the parties' briefs establishes that the findings and 

conclusions of the National Futures Association ("NF A") Appeals Committee are supported by 

the weight of the evidence and we therefore adopt them. We also find that none of the 

respondents' arguments on appeal raise important questions of law or policy. Accordingly, we 

summarily affirm the decision of the NFA Appeals Committee. 

Michael E. Rose ("Rose") and Martin H. Bedick ("Bedick") were found to have violated 

NF A Compliance Rule 2-4 (failing to observe high standards of commercial honor and just and 

equitable principles of trade) in the exercise of their duties as principals of Angus Jackson, Inc. 

of Florida, an introducing broker and NFA Member. Bedick and Angus Jackson were also found 

to have violated NF A Compliance Rule 2-2(f) for willfully submitting false or misleading 

information to NF A. Angus Jackson was further found to have violated NF A Bylaws 110 I and 

301 (b) by conducting futures business with a non-NF A Member and permitting an unregistered 
individual to act as an associated person of the firm. Angus Jackson was also found to have 

violated NFA Compliance Rules 2-9(c) (failing to develop and implement an adequate antimoney laundering program) and 2-26 (co-mingling customer and non-customer orders and 

improper post-execution of bunched customer orders). 

NF A imposed upon Rose a two-year ban from registration and a permanent ban against 

acting as a principal of any NF A Member. NF A imposed upon Bedick a seven-year ban from 

registration and a permanent ban against acting as a principal of any NF A Member. It imposed 

upon Angus Jackson a seven-year ban from acting as a principal of any NF A Member, and a 

$25,000 fine in the event that Angus Jackson applies for and is granted NF A membership or 

principal status in the future. 

The appeals of Rose, Bedick, and Angus Jackson have not established the clear error 

required for a reversal of a final decision ofthe NFA in a disciplinary action as set forth in 

Commission Regulation 171.34(a), 17 C.F.R. § 171.34(a). 1 

Section 17(i) of the Commodity Exchange Act provides that, during a review of a final 

disciplinary action taken by a registered futures association against a member, "if the 

Commission finds that the member or person associated with a member has engaged in the acts 

or practices, or has omitted the acts, that the association has found the member or person to have 

engaged in or omitted; the acts or practices, or omissions to act, are in violation of the rules of 

1 On appeal, Rose argues that he did not have executive responsibilities at Angus Jackson; that he reasonably 

believed that Angus Jackson was in compliance with all applicable laws; and that he had no reasonable duty to 

suspect foul play. Rose argues that the Appeals Committee's decision should be set aside, or, if not set aside, the 

penalty reduced to one year including time served. Bedick and Angus Jackson argue on appeal that a person is 

either exempt from registration as a commodity trade advisory ("CTA"} pursuant to 7 U.S.C. § 6m and 17 C.F.R. 

4.14(a)( I} or not, and that they should not have been required to prove CT A status of a person to whom they paid 

commissions. Bedick and Angus Jackson further argue that the sanctions imposed by the NFA are inappropriate 

based on the specific facts of this case. Bedick and Angus Jackson argue that if a sanction is imposed, it should be 

limited to no more than a one-year suspension. We do not find these arguments persuasive. Additionally, the 

sanctions imposed upon respondents are consistent with those the NF A has imposed in similar circumstances, and 

Rose, Bedick, and Angus Jackson have not met their burden of showing that the sanctions here are oppressive or 

excessive in light ofthe violation found. 

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the association specified in the determination ofthe association; and such rules are, and were 

applied in a manner, consistent with the purposes of this Act, the Commission, by order, shall so 

declare and, as appropriate, affirm the sanction imposed by the association .... " 7 U.S.C. 

§ 21(i)(l)(A). Additionally, 17 C.F.R. §171.33(b) provides that where the Commission finds 

that the result reached by the NFA is "substantially correct and that none of the arguments on 

appeal made by the appellant[s] raise important questions of law or policy, the Commission 

may ... summarily affirm the decision without opinion." The decision of the Appeals Committee 

is supported by the weight of the evidence, is not clearly erroneous, and the sanctions levied are 

neither excessive nor oppressive in light of the violations found? 

IT IS SO ORDERED. 

By the Commission (Chairman GENSLER and Commissioners CHILTON, O'MALIA, and 

WETJEN.) 

Melissa D. Jurgens 

Secretary of the Commi sion 

Commodity Futures Trading Commission 

Dated: December 2, 2013 

2 Pursuantto Commission Regulation 171.33(b ), 17 C.F.R. § 171.33(b), neitherthe Commission's order of summary 

affirmance nor the NF A's underlying order shall serve as Commission precedent in other proceedings. 

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