Chicago Mercantile Exchange Inc. - NOTICE OF DISCIPLINARY ACTION

FILE NO:               23-CH-2327

MEMBER FIRM:     Straits Finanical L.L.C.

CME Rule:              980. REQUIRED RECORDS AND REPORTS (in part)

                               G.  Each Clearing Member must submit daily reports that include all information required by the Clearing House, including but not limited to legal entity identifiers, where available, and end-of-day gross positions by each house origin, by each customer origin and by each individual customer-level account within each customer origin. Daily reporting of individual customer-level account information pursuant to this paragraph does not oblige a clearing FCM to look through an omnibus account that it clears for a carrying broker to the underlying customer account.

FINDINGS:             On January 18, 2024, the Clearing House Risk Committee (“CHRC”) found that Straits Financial LLC (“Straits”) was inaccurately reporting their Customer Gross Margin (“CGM”) file at the account controller level and not at the level of individual customers. The CHRC thereby concluded that Straits violated CME Rule 980.G and CME CGM Technical Overview Requirements. Straits submitted an offer of settlement in which it neither admitted nor denied the rule violation upon which the penalty is based.      

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

EFFECTIVE DATE:         JANUARY 19, 2024