NOTICE OF DISCIPLINARY ACTION

FILE NO.:                   20-CH-2005

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:

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 an adequate accounting system, internal accounting controls, and procedures for safeguarding customer and firm assets. This includes, but is not limited to, the following:                                                

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.1. and 980.B.

PENALTY:                  In accordance with the settlement offer, the Committee imposed a $100,000 fine.

EFFECTIVE DATE:    August 21, 2020