As set forth below, the CFTC respectfully requests that the Court enter the proposed Consent Order because it is fair, reasonable, and within the public interest. The CFTC notes the preliminary nature of the proposed Consent Order, and underscores its necessity given Deutsche Bank’s past and ongoing violations of the Commodity Exchange Act (“Act”), 7 U.S.C. § 1 et seq. (2012), Commission Regulations (“Regulations”), 17 C.F.R. § 1.1 et seq. (2016) and the CFTC Order entered against Deutsche Bank in September 2015 (“CFTC Order”), CFTC Dkt. No. 15-40.

Venue properly lies with this Court pursuant to Section 6c(e) of the Act, 7 U.S.C. § 13a- 1(e), since Defendants are found in, inhabit, or transact business in this District. III. THE PARTIES Plaintiff Commodity Futures Trading Commission (“Commission” or “CFTC”) is an independent federal regulatory agency that is charged by Congress with administering and enforcing the provisions of the Act (2006 and Supp. 2009), as amended by the Dodd-Frank Act, to be codified at 7 U.S.C. §§ 1 et seq., and the Commission Regulations promulgated thereunder, 17 C.F.R. §§ 1.1 et seq. (2012). Defendant Peregrine Financial Group Inc. (“PFG”) is registered with the Commission as a futures commission merchant (“FCM”) and notice-registered broker-dealer.

II. The Parties The Commission is a federal agency tasked with administering and enforcing the Commodity Exchange Act (the "CEA"), 7 U.S.C. §§ I et seq., and promulgating and enforcing regulations thereunder, 17 C.F.R. §§ 1.1, et seq. (Compl., 9.) Parnon is a corporation organized under the laws of Texas, with its principal place ofbusiness in Rancho Santa Fe, California.