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CFTC ·

US District Court enters consent order banning Andrew Middlebrooks and EIA All Weather Alpha Fund from CFTC registration and commodity trading activity

Commodity pool operators cannot engage Middlebrooks or EIA All Weather Alpha Fund for CFTC-registered or client-trading activities because the consent order permanently bars trading-for-others, solicitation/acceptance of trading funds, and CFTC registration

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The U.S. District Court for the Eastern District of Michigan entered a CFTC consent order against Andrew Middlebrooks and EIA All Weather Alpha Fund I Partners LLC that permanently bans them from further Commodity Exchange Act and CFTC regulation violations, from trading for others, from soliciting or accepting funds for trading, and from registering with the CFTC.
Why it matters
The consent order creates a permanent legal boundary that blocks the defendants from operating in roles that require trading for others, raising/holding client trading funds, or CFTC registration; any attempt to operate a commodity pool or related solicitation/trading-for-others activity would violate the order’s permanent prohibitions.
Implications
  • — Commodity pool operators’ compliance teams must block any onboarding or engagement of Andrew Middlebrooks or EIA All Weather Alpha Fund I Partners LLC for trading-for-others or commodity pool activities — engaging barred persons breaches the court-ordered permanent prohibitions on trading for others and soliciting/accepting funds for trading.
  • — Futures commission merchants’ onboarding and surveillance teams must prevent account opening or trading access that enables Andrew Middlebrooks or EIA All Weather Alpha Fund I Partners LLC to trade for others or solicit/accept customer funds for trading — providing such access conflicts with the permanent bans imposed by the consent order.
Who is affected
  • — Commodity pool operators’ compliance teams
  • — Futures commission merchants’ onboarding and surveillance teams
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