HANA FINANCIAL INVESTMENT
EXCHANGE RULE VIOLATIONS:
432. GENERAL OFFENSES (IN PART)
It shall be an offense:
I. to make a verbal or written material misstatement to the Board, a committee, or Exchange employees;
L.2. to fail to fully answer all questions or produce all books and records at such hearing or in connection with any investigation, or to make false statements;
Q. to commit an act which is detrimental to the interest or welfare of the Exchange or to engage in any conduct which tends to impair the dignity or good name of the Exchange;
W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.
Pursuant to an offer of settlement in which Hana Financial Investment (“Hana”) neither admitted nor denied the rule violations upon which the penalty is based, on December 5, 2018, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that on multiple occasions during the time period of May 2017 through May 2018, Hana impeded the Exchange’s investigation into the trading activity of Hana’s customers by: 1) failing to have appropriate procedures and protocols in place to maintain accurate audit trail and customer account information, including records of Tag 50 IDs registered to trade customer accounts, and log-in/log-out information of the Tag 50 ID users; and 2) failing to provide timely, complete and accurate responses to the Exchange’s multiple investigatory requests for records related to account ownership, authorized traders for accounts, audit trail data, and account statements.
The Panel found that as a result, Hana violated Rules 432.I., 432.L.2., 432.Q. and 432.W.
In accordance with the settlement offer and taking into consideration the Summary Access Denial previously imposed against Hana, the Panel ordered Hana to pay a fine to the Exchange in the amount of $425,000.
December 7, 2018