• NOTICE OF DISCIPLINARY ACTION

      • #
      • CBOT-18-0995-BC
      • Effective Date
      • 26 April 2019
    • FILE NO.:

      CBOT 18-0995-BC

      MEMBER:

      Arches Asset Management, LLC

      CBOT RULE VIOLATIONS:

      Rule 562 (“Position Limit Violations”) (in part)

      Any positions, including positions established intraday, in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

      FINDINGS:

      Pursuant to an offer of settlement in which Arches Asset Management LLC (“Arches”) neither admitted nor denied the rule violation or factual findings upon which the penalty is based, on April 24, 2019, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that at the close of business on July 30, 2018, and into July 31, 2018, Arches held an aggregate net futures equivalent short position in AUG2018 Soybean Oil futures that exceeded the spot month position limit of 540 contracts by 460 contracts (85.2%). Arches incurred a $966 net profit from liquidating that overage.

      The Panel concluded that Arches thereby violated CBOT Rule 562.

      PENALTY:

      In accordance with the settlement offer, the Panel ordered Arches to pay a fine of $40,000 and disgorgement of $966.

      EFFECTIVE DATE:

      April 26, 2019