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addition adjudicators administrative agencies ALJ's appeals applied appropriate assessing sanctions authority CBOT cease and desist CFTC Docket CFTC Regulation CFTC staff CFTC's civil money penalties civil penalty Comm Commission Commission's Commodity Exchange Act commodity pool commodity trading advisors conduct consider consistency cooperate criminal database desist order deter determining disciplinary actions disciplinary committee Division of Enforcement exchange factors FCCB federal financial condition financial violations fines floor recordkeeping violations futures exchanges Futures Trading gravity Halper imposing sanctions imposition individual member firm NYCE NYFE offenses penalties assessed penalty amounts prior Privilege Revocation procedures proceedings recidivism recidivists registration regulatory respondent's respondents response variables restitution result rule enforcement reviews rule violations sanctions imposed settlement specific SRO disciplinary statistical statute statutory study period suspension trade practice violations Transfer Binder types of violations violation type wrongdoing