CHICAGO BOARD OF TRADE
NOTICE OF DISCIPLINARY ACTION
FILE NO.: 14-CH-1408
MEMBER FIRM: Bunge Chicago, Inc.
970. FINANCIAL REQUIREMENTS
A. Subject to exemptions granted by Exchange staff, all clearing members, including non-FCMs, must comply with the requirements set forth in CFTC Regulations 1.10, 1.12, 1.17 and 1.18. This includes, but is not limited to, the following:
1. Maintenance of minimum capital requirements of at least $5 million except that a clearing member that is a bank must maintain minimum Tier I Capital (as defined in accordance with regulation applicable to the relevant bank) of at least $5 billion.
980. REQUIRED RECORDS AND REPORTS
B. Each clearing member shall maintain and adequate accounting system, internal accounting controls, and procedures for safeguarding customer and firm assets. This includes, but is not limited to, the following:
3. Prevention of a material inadequacy as defined in CFTC Regulation 1.16(d)(2).
FINDINGS: Pursuant to an offer of settlement in which Bunge Chicago, Inc. neither admitted nor denied the rule violation upon which the penalty is based, on June 19, 2014, the Clearing House Risk Committee found that Bunge Chicago, Inc. violated CBOT Rules 970.A.1. and 980.B.3.
PENALTY: In accordance with the settlement offer, the Committee fined Bunge Chicago, Inc $25,000.
EFFECTIVE DATE: June 20, 2014
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