NOTICE OF SUMMARY ACTION

FILE NO.:

COMEX-20-1345

MEMBER FIRM:

Typhon Capital Management, LLC

COMEX RULE VIOLATION:

526.F. BLOCK TRADES

Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

MRAN RA-2109-5 (in part)

Market participants must accurately report the execution time of the block trade.

FINDINGS:

On 17 occasions in May 2020, September 2020, and October 2020, Typhon Capital Management, LLC did not report block trades with an accurate execution time to the Exchange. These block trades were executed in June 2020, August 2020, October 2020, November 2020, and January 2021 Copper Futures.

PENALTY:

On February 9, 2022, pursuant to Rule 512, a fine in the amount of $5,000 was assessed against Typhon Capital Management, LLC for its violations of COMEX Rule 526 and CME Rule 526.F.

EFFECTIVE DATE:

March 25, 2022