• NOTICE OF DISCIPLINARY ACTION

      • #
      • CBOT-18-0927-BC
      • Effective Date
      • 26 April 2019
    • FILE NO.:

      CBOT 18-0927-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 April 16, 2018, and into April 17, 2018, Arches held an aggregate net futures equivalent short position in JULY2018 Soybean Meal futures that exceeded the single month position limit of 6,500 contracts by 73.650 contracts (1.1%). The Panel also found that on April 18, 2018, Arches exceeded the position limit intraday by 288.359 contracts (4.4%). Arches did not profit from liquidating these overages.

      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 $15,000.

      EFFECTIVE DATE:

      April 26, 2019