NOTICE OF SUMMARY ACTION

FILE NO.:

CME DQA -24-1368

MEMBER FIRM:

Cunningham Commodities, LLC

RULE VIOLATION:   

536.     RECORDKEEPING REQUIREMENTS FOR PIT, GLOBEX AND NEGOTIATED TRADES

F.  CTR Enforcement Program and Sanction Schedule

(In pertinent part)

The Market Regulation Department will conduct audits of clearing members in order to verify the accurate recording and submitting of required audit trail information.

FINDINGS:

Pursuant to the results of a back-office CTR exam, for trade dates November 8, 2023, through December 27, 2023, Cunningham Commodities, LLC data entry errors exceeded the 10% threshold level mandated by Rule 536.F.

PENALTY:

Pursuant to the Rule 536.F sanction schedule, Cunningham Commodities, LLC was issued a $2,500 fine on January 29, 2024, for its first violation of Rule 536.F. within 24 months.

EFFECTIVE DATE:

February 14, 2024