14. The vast majority of Hold Brothersâ traders located overseas were associated with one of two âcustomers,â either Trade Alpha in 2009 or Demostrate in 2010 (hereinafter, collectively, âDemostrateâ or the âDemostrate tradersâ). These traders traded Demostrateâs capital and were monitored for risk and compliance purposes by personnel of Hold Brothers and a Hold Brothers affiliate. As an owner, Steve Hold shared in the Demostrate trading profits. Unlike Hold Brothersâ proprietary traders, however, Hold Brothers did not consider the Demostrate traders to be associated with the firm, nor did any of these traders hold licenses from any self-regulatory organization.
15. Demostrate maintained a brokerage account at Hold Brothers. Demostrateâs managing member was Tobias. Demostrate was Hold Brothersâ largest âcustomer,â both in terms of the number of trades and revenues generated. All Demostrate trading occurred in a single account held at Hold Brothers. All of the persons who traded through Demostrateâs account were located outside the United States, primarily in China. Hold Brothers assisted Demostrate and its traders in accessing the securities markets by providing these foreign traders with access to front-end trading platforms and access to the U.S. securities markets.
http://sec.gov/litigation/admin/2012/34-67924.pdf
15. Demostrate maintained a brokerage account at Hold Brothers. Demostrateâs managing member was Tobias. Demostrate was Hold Brothersâ largest âcustomer,â both in terms of the number of trades and revenues generated. All Demostrate trading occurred in a single account held at Hold Brothers. All of the persons who traded through Demostrateâs account were located outside the United States, primarily in China. Hold Brothers assisted Demostrate and its traders in accessing the securities markets by providing these foreign traders with access to front-end trading platforms and access to the U.S. securities markets.
http://sec.gov/litigation/admin/2012/34-67924.pdf