THE Securities and Futures Appeal Tribunal has upheld a decision handed down by the Securities and Futures Commission to revoke the registration of Kingly Commodities as a commodity dealer. In dismissing Kingly's appeal, the tribunal ordered the company to pay the SFC $1.1 million in costs. Kingly's determination to avoid losing its licence was evident by its hiring of Anthony Francis Neoh, QC, a member of the Stock Exchange of Hong Kong council. Kingly, which dealt on behalf of clients in futures contracts on the Manila International Futures Exchange, was raided by the SFC last February after a number of complaints from investors. The company lost its brokerage licence in March after an SFC investigation. In July, the SFC said the decision to revoke Kingly's registration was based on four grounds, including its use of unregistered dealer's representatives and the use, on an institutional basis, of cold calling. The SFC also cited a number of complaints that Kingly had failed to promptly close clients' positions when requested by clients and failed to promptly pay account balances due to clients when requested to do so. Much of this evidence was uncovered during the SFC raid. One of the complaints related to sales representative Michael Tang, who wrote in note dated December 17, 1992 that a client ''has demanded to be exited from the market . . . I had tried to stall her many times to the point where she is threatening to come up to the office and executing her own clearance form and then sue the company afterwards for disregarding her wishes''. Another reason for the SFC decision was the movement of client funds between Kingly and its agent in Manila, Kingly Commodities Traders and Multi Resources, in a manner that was, or was likely to be, prejudicial to client interests. The SFC cited these reasons in refusing Kingly's application for registration as a commodity trading adviser on September 3, 1993. After Kingly appealed, a hearing of the appeals tribunal was held last month to consider both the revocation and the refusal of Kingly's application for registration. The tribunal said it had ''no doubt that each charge is sufficiently serious to warrant the revocation of [Kingly's] licence''. It ruled: ''The first charge discloses a blatant disregard of the requirement that dealer's representatives must be registered. This is a requirement for the protection of the investment public. A company which has [flouted] this requirement should have its licence revoked.'' The SFC found that of the 123 employees recorded in Kingly's daily business reports, 111 received commissions and a basic salary and 83 were never registered as dealer's representatives. The SFC found that even the 28 employees who were registered had generated commissions before they became registered.