FILE NO:         24-CH-2402

MEMBER FIRM:  Wedbush Securities, Inc.

CME Rule:        982. Risk Management

All clearing members must have written risk management policies and procedures in place to ensure they are able to perform certain basic risk and operational functions at all times. At a minimum, the following areas must be considered in the firm’s policies and procedures, depending on the firm’s size and its business and product mix:

A. Trade Submission and Account Monitoring. Clearing members must have procedures in place to demonstrate compliance in the following areas for trades executed through both electronic platforms and open outcry:

1. Monitoring the credit risks of accepting trades, including give-up 
trades, of specific customers.

        2. Monitoring the risks associated with proprietary trading.

3. Limiting the impact of significant market moves through the use of    tools such as stress testing or position limits.

4. Maintaining the ability to monitor account activity on an           intraday basis, including overnight.

5. Ensuring order entry systems include the ability to set    automated credit controls or position limits or requiring a firm employee to enter orders.

6. Defining sources of liquidity for increased settlement obligations.

7. Determining a risk profile for each account it carries, including whether such account presents a heightened risk profile.

B. Additional and/or Alternative Requirements. Exchange or Clearing House staff may prescribe additional and/or alternative requirements in order for clearing members to comply with this Rule.

C. Each clearing member shall promptly provide to Clearing House staff, upon request, information and documents regarding its risk management policies, procedures and practices, including, without limitation, information and documents relating to the liquidity of its financial resources, settlement procedures and operational issues.

D. Each clearing member shall make information and documents regarding its risk management policies, procedures and practices available to the CFTC upon the CFTC’s request. In addition, all FCM clearing membersmust comply with the risk management requirements set forth in CFTC Regulation 1.11: Risk Management Program for futures commission merchants.

FINDINGS:      Pursuant to an offer of settlement in which Wedbush Securities, Inc.                               ("Wedbush") neither admitted nor denied the rule violation upon which the                         penalty is based, on October 10, 2024, the Clearing House Risk Committee                         ("CHRC") found that Wedbush had insufficient risk management policies,                                procedures and controls in place to ensure the performance of certain risk                         and operational functions, including the adequate monitoring of trading                          activity at all times. The CHRC thereby concluded that Wedbush violated                         CME Rule 982.

 PENALTY:     In accordance with the settlement offer, the CHRC imposed a $1,000,000 fine.

EFFECTIVE DATE: October 11, 2024