NOTICE OF DISCIPLINARY ACTION

BOARD OF TRADE OF THE CITY OF CHICAGO, INC.

NOTICE OF DISCIPLINARY ACTION

FILE NO.: 16-CH-1609

MEMBER FIRM: CHS Hedging, LLC

CBOT RULE: 970. FINANCIAL REQUIREMENTS

C. In conjunction with the requirements set forth in CFTC Regulations 1.10, 1.12, 1.17, and 1.18, clearing members must comply with the following requirements:

2. Submit a certified Form 1-FR or FOCUS Report as of the clearing member’s fiscal yearend within the time requirements set forth in CFTC Regulation 1.10. A clearing member must include with its certified Form 1-FR or FOCUS Report, a reconciliation from the certified Form 1-FR or FOCUS Report to the monthly Form 1-FR or FOCUS Report as of the same date or a statement that no differences were noted.                                                           

FINDINGS: Pursuant to an offer of settlement in which CHS Hedging, LLC neither admitted nor denied the rule violation upon which the penalty is based, on January 26, 2017, the Clearing House Risk Committee found that CHS Hedging, LLC violated CBOT Rule 970.C.2.

PENALTY: In accordance with the settlement offer, the Committee imposed a $25,000 fine.

EFFECTIVE DATE:   January 27, 2017