NOTICE OF DISCIPLINARY ACTION

CHICAGO BOARD OF TRADE, INC.

NOTICE OF DISCIPLINARY ACTION

FILE NO.: 16-CH-1601

MEMBER FIRM: Cunningham Commodities, LLC

CBOT RULE: 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:

    4. Completely and accurately computing and recording the balances in the net capital computation including capital requirements.     

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 August 25, 2016, the Clearing House Risk Committee found that Cunningham Commodities, LLC violated CBOT Rule 970.A.4.

PENALTY: In accordance with the settlement offer, the Committee imposed a $50,000 fine.  

EFFECTIVE DATE:   August 26, 2016