NOTICE OF DISCPLINARY ACTION

FILE NO.:                   20-CH-2004

MEMBER FIRM:         Cunningham Commodities, LLC   

CBOT Rules:              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;

980. REQUIRED RECORDS AND REPORTS

B. Each clearing member shall maintain an adequate accounting system, internal accounting controls, and procedures for safeguarding customer and firm assets.                          

FINDINGS:                 Pursuant to an offer of settlement in which Cunningham Commodities, LLC neither admitted nor denied the rule violations upon which the penalty is based, on August 20, 2020, the Clearing House Risk Committee found that Cunningham Commodities, LLC violated CBOT Rules 970.A.4. and 980.B.

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

EFFECTIVE DATE:    August 21, 2020