NOTICE OF DISCIPLINARY ACTION

MEMBER FIRM:

Cunningham Commodities, LLC

CBOT RULE VIOLATIONS:

Rule 807 Open Long Positions During Delivery Month

At such times and in such manner as shall be prescribed by the Manual, clearing members shall submit a complete and accurate record of dates of all open purchases for use in making deliveries. Clearing members shall be fully responsible for inventories submitted to the Clearing House. This rule shall not apply to trading in options markets.

FINDINGS:

Pursuant to an offer of settlement in which Cunningham Commodities, LLC (“Cunningham”) neither admitted nor denied the rule violation upon which the penalty is based, on May 10, 2017, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on November 2, 2015, and twice on November 10, 2015, Cunningham did not accurately report its long positions eligible for delivery. On November 2, 2015, Cunningham inaccurately reported its long position for delivery in the November 2015 Rough Rice futures contract. On November 10, 2015, Cunningham failed to report its long positions eligible for delivery in the November 2015 Rough Rice futures contract and the November 2015 Soybean futures contract. The foregoing resulted in incorrect delivery assignments in the Rough Rice futures contract. The Panel concluded that Cunningham thereby violated CBOT Rule 807.

PENALTY:

In accordance with the settlement offer, the Panel ordered Cunningham to pay a fine of $50,000.

EFFECTIVE DATE:

May 12, 2017