CHICAGO BOARD OF TRADE
NOTICE OF DISCIPLINARY ACTION
FILE NO.: 14-CH-1407
MEMBER FIRM: Cunningham Commodities, LLC
CBOT RULE: 971. SEGREGATION, SECURED AND CLEARED SWAPS CUSTOMER ACCOUNT REQUIREMENTS
A. All clearing members must comply with the requirements set forth in CFTC Regulations 1.20 through 1.30, 1.32, 1.49 and 30.7, and Part 22 of the CFTC Regulations. This includes, but is not limited to, the following:
1. Maintaining sufficient funds at all times in segregation, secured 30.7 and Cleared Swaps Customer accounts.
FINDINGS: Pursuant to an offer of settlement in which Cunningham Commodities, LLC neither admitted nor denied the rule violation upon which the penalty is based, on June 19, 2014, the Clearing House Risk Committee found that Cunningham Commodities, LLC violated CBOT Rule 971.A.1.
PENALTY: In accordance with the settlement offer, the Committee fined Cunningham Commodities, LLC $25,000.
EFFECTIVE DATE: June 20, 2014
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