Dunn Capital Management, Llc

Allegations: A SUBCOMMITTEE OF THE EXCHANGE'S BUSINESS CONDUCT COMMITTEE ("BCC SUBCOMMITTEE") DETERMINED THAT ON VARIOUS DAYS BETWEEN SEPTEMBER 2016 AND MAY 2017, DUNN CAPITAL MANAGEMENT ("DUNN CAPITAL"), THROUGH THE ACTIVITY OF A FORMER EMPLOYEE, MAY HAVE VIOLATED EXCHANGE RULES 4.02(L)(1)(A), 4.02(L)(2), 4.04, AND 4.15(B). SPECIFICALLY, THE FORMER EMPLOYEE, WHILE SOMETIMES USING THE TRADER ID OF A COLLEAGUE INSTEAD OF HIS OWN, APPEARED TO HAVE ENTERED AND CANCELLED ORDERS DURING THE PRE-OPEN OF VARIOUS MARKETS WITHOUT THE INTENT TO TRADE, BUT INSTEAD WITH THE INTENT TO DETERMINE THE EFFECT THESE ORDERS WOULD HAVE ON THE INDICATIVE OPENING PRICE. SEPARATELY, THE BCC SUBCOMMITTEE DETERMINED THAT DUNN CAPITAL MAY HAVE VIOLATED EXCHANGE RULE 4.01(A) BY FAILING TO SUPERVISE THE EXCHANGE-RELATED ACTIVITIES OF THE FORMER EMPLOYEE. DUNN CAPITAL DID NOT PROFIT FROM THE FORMER EMPLOYEE'S ACTIVITY. Status: Final Sanction Detail: A SUBCOMMITTEE OF THE EXCHANGE'S BUSINESS CONDUCT COMMITTEE ("BCC SUBCOMMITTEE") DETERMINED THAT ON VARIOUS DAYS BETWEEN SEPTEMBER 2016 AND MAY 2017, DUNN CAPITAL MANAGEMENT ("DUNN CAPITAL"), THROUGH THE ACTIVITY OF A FORMER EMPLOYEE, MAY HAVE VIOLATED EXCHANGE RULES 4.02(L)(1)(A), 4.02(L)(2), 4.04, AND 4.15(B). SPECIFICALLY, THE FORMER EMPLOYEE, WHILE SOMETIMES USING THE TRADER ID OF A COLLEAGUE INSTEAD OF HIS OWN, APPEARED TO HAVE ENTERED AND CANCELLED ORDERS DURING THE PRE-OPEN OF VARIOUS MARKETS WITHOUT THE INTENT TO TRADE, BUT INSTEAD WITH THE INTENT TO DETERMINE THE EFFECT THESE ORDERS WOULD HAVE ON THE INDICATIVE OPENING PRICE. SEPARATELY, THE BCC SUBCOMMITTEE DETERMINED THAT DUNN CAPITAL MAY HAVE VIOLATED EXCHANGE RULE 4.01(A) BY FAILING TO SUPERVISE THE EXCHANGE-RELATED ACTIVITIES OF THE FORMER EMPLOYEE. DUNN CAPITAL DID NOT PROFIT FROM THE FORMER EMPLOYEE'S ACTIVITY. DUNN CHOSE TO SETTLE THE MATTER WITH A SETTLEMENT OF $40,000 RATHER THAN LITIGATE THE ALLEGATION. THE TRADER INVOLVED RESIGNED AND WAS SUSPENDED FROM TRADING ON THE ICE FUTURES US EXCHANGE FOR SIX MONTHS. Summary: A SUBCOMMITTEE OF THE EXCHANGE'S BUSINESS CONDUCT COMMITTEE ("BCC SUBCOMMITTEE") DETERMINED THAT ON VARIOUS DAYS BETWEEN SEPTEMBER 2016 AND MAY 2017, DUNN CAPITAL MANAGEMENT ("DUNN CAPITAL"), THROUGH THE ACTIVITY OF A FORMER EMPLOYEE, MAY HAVE VIOLATED EXCHANGE RULES 4.02(L)(1)(A), 4.02(L)(2), 4.04, AND 4.15(B). SPECIFICALLY, THE FORMER EMPLOYEE, WHILE SOMETIMES USING THE TRADER ID OF A COLLEAGUE INSTEAD OF HIS OWN, APPEARED TO HAVE ENTERED AND CANCELLED ORDERS DURING THE PRE-OPEN OF VARIOUS MARKETS WITHOUT THE INTENT TO TRADE, BUT INSTEAD WITH THE INTENT TO DETERMINE THE EFFECT THESE ORDERS WOULD HAVE ON THE INDICATIVE OPENING PRICE. SEPARATELY, THE BCC SUBCOMMITTEE DETERMINED THAT DUNN CAPITAL MAY HAVE VIOLATED EXCHANGE RULE 4.01(A) BY FAILING TO SUPERVISE THE EXCHANGE-RELATED ACTIVITIES OF THE FORMER EMPLOYEE. DUNN CAPITAL DID NOT PROFIT FROM THE FORMER EMPLOYEE'S ACTIVITY. DUNN CHOSE TO SETTLE THE MATTER WITH A SETTLEMENT OF $40,000 RATHER THAN LITIGATE THE ALLEGATION. THE TRADER INVOLVED RESIGNED AND WAS SUSPENDED FROM TRADING ON THE ICE FUTURES US EXCHANGE FOR SIX MONTHS.