Dissenting Statement by Commissioner Sharon Y. Bowen Regarding TeraExchange LLC

September 24, 2015

I believe fictitious trading deserves a penalty.  Tera Exchange facilitated wash trading and prearranged trading in violation of the Commodity Exchange Act.  That is why we brought this case.  I fundamentally disagree with the notion that they deserve no penalty.  Accordingly, I dissent.

Last Updated: September 24, 2015