Fig Llc

Allegations: IN LATE OCTOBER 2010, THE CME GROUP MARKET REGULATION DEPARTMENT ("CME") NOTIFIED FORTRESS THAT IT WAS APPROACHING A SINGLE MONTH SPECULATIVE POSITION LIMIT OF THE CHICAGO BOARD OF TRADE ("CBOT"), A DESIGNATED CONTRACT MARKET OF THE CME, IN WHEAT FUTURES CONTRACTS. UPON RECEIVING THAT NOTIFICATION, THE FIRM IMMEDIATELY REVIEWED ITS POSITION, AND AFTER CONCLUDING THAT IT HAD IN FACT EXCEEDED THE SPECULATIVE POSITION LIMIT, QUICKLY REDUCED THE EXCESS POSITION AND BROUGHT THE POSITION BACK INTO COMPLIANCE WITH THE APPLICABLE LIMIT. ON AUGUST 24, 2012, THE CME INITIATED AN ACTION BEFORE THE CBOT BUSINESS CONDUCT COMMITTEE ("BCC") BASED ON THE VIOLATION THAT OCCURRED IN OCTOBER 2010, SEEKING PENALTIES AND DISGORGEMENT OF APPROXIMATELY $350,000 IN PROFITS RESULTING FROM THE EXCESS POSITION. THE OCTOBER 2010 VIOLATION INVOLVED AN UNINTENTIONAL OVERAGE OF APPROXIMATELY 7%, WHICH WAS CORRECTED WITHIN APPROXIMATELY THREE REGULAR TRADING HOURS. FORTRESS CHOSE TO DEFEND THE ACTION RATHER THAN SETTLING IT, ARGUING THAT, BASED ON APPLICABLE RULES, THE APPROPRIATE SANCTION WAS ONLY A WARNING LETTER. THIS WAS FORTRESS' FIRST EVER VIOLATION OF ANY CBOT, CME OR CFTC RULE. PRIOR TO THE VIOLATION, FORTRESS WAS IN THE PROCESS OF IMPLEMENTING AN AUTOMATED SYSTEM TO MONITOR APPLICABLE LIMITS ACROSS CLIENT ACCOUNTS. SHORTLY AFTER THE VIOLATION, FORTRESS COMPLETED THE IMPLEMENTATION, AND THERE HAVE BEEN NO SUBSEQUENT POSITION LIMIT VIOLATIONS. ON NOVEMBER 27, 2012, FORTRESS APPEARED BEFORE THE BCC IN A CONTESTED HEARING AND WAS FINED $90,000 AND ORDERED TO PAY DISGORGEMENT OF APPROXIMATELY $350,000. ON JANUARY 28, 2013, FORTRESS APPEALED THE BCC RULING, AND THE APPELLATE PANEL OF THE CME AFFIRMED THE BCC DECISION ON JUNE 19, 2013. Status: Final Sanction Detail: IN LATE OCTOBER 2010, THE CME GROUP MARKET REGULATION DEPARTMENT ("CME") NOTIFIED FORTRESS THAT IT WAS APPROACHING A SINGLE MONTH SPECULATIVE POSITION LIMIT OF THE CHICAGO BOARD OF TRADE ("CBOT"), A DESIGNATED CONTRACT MARKET OF THE CME, IN WHEAT FUTURES CONTRACTS. UPON RECEIVING THAT NOTIFICATION, THE FIRM IMMEDIATELY REVIEWED ITS POSITION, AND AFTER CONCLUDING THAT IT HAD IN FACT EXCEEDED THE SPECULATIVE POSITION LIMIT, QUICKLY REDUCED THE EXCESS POSITION AND BROUGHT THE POSITION BACK INTO COMPLIANCE WITH THE APPLICABLE LIMIT. ON AUGUST 24, 2012, THE CME INITIATED AN ACTION BEFORE THE CBOT BUSINESS CONDUCT COMMITTEE ("BCC") BASED ON THE VIOLATION THAT OCCURRED IN OCTOBER 2010, SEEKING PENALTIES AND DISGORGEMENT OF APPROXIMATELY $350,000 IN PROFITS RESULTING FROM THE EXCESS POSITION. THE OCTOBER 2010 VIOLATION INVOLVED AN UNINTENTIONAL OVERAGE OF APPROXIMATELY 7%, WHICH WAS CORRECTED WITHIN APPROXIMATELY THREE REGULAR TRADING HOURS. FORTRESS CHOSE TO DEFEND THE ACTION RATHER THAN SETTLING IT, ARGUING THAT, BASED ON APPLICABLE RULES, THE APPROPRIATE SANCTION WAS ONLY A WARNING LETTER. THIS WAS FORTRESS' FIRST EVER VIOLATION OF ANY CBOT, CME OR CFTC RULE. PRIOR TO THE VIOLATION, FORTRESS WAS IN THE PROCESS OF IMPLEMENTING AN AUTOMATED SYSTEM TO MONITOR APPLICABLE LIMITS ACROSS CLIENT ACCOUNTS. SHORTLY AFTER THE VIOLATION, FORTRESS COMPLETED THE IMPLEMENTATION, AND THERE HAVE BEEN NO SUBSEQUENT POSITION LIMIT VIOLATIONS. ON NOVEMBER 27, 2012, FORTRESS APPEARED BEFORE THE BCC IN A CONTESTED HEARING AND WAS FINED $90,000 AND ORDERED TO PAY DISGORGEMENT OF APPROXIMATELY $350,000. ON JANUARY 28, 2013, FORTRESS APPEALED THE BCC RULING, AND THE APPELLATE PANEL OF THE CME AFFIRMED THE BCC DECISION ON JUNE 19, 2013. Summary: IN LATE OCTOBER 2010, THE CME GROUP MARKET REGULATION DEPARTMENT ("CME") NOTIFIED FORTRESS THAT IT WAS APPROACHING A SINGLE MONTH SPECULATIVE POSITION LIMIT OF THE CHICAGO BOARD OF TRADE ("CBOT"), A DESIGNATED CONTRACT MARKET OF THE CME, IN WHEAT FUTURES CONTRACTS. UPON RECEIVING THAT NOTIFICATION, THE FIRM IMMEDIATELY REVIEWED ITS POSITION, AND AFTER CONCLUDING THAT IT HAD IN FACT EXCEEDED THE SPECULATIVE POSITION LIMIT, QUICKLY REDUCED THE EXCESS POSITION AND BROUGHT THE POSITION BACK INTO COMPLIANCE WITH THE APPLICABLE LIMIT. ON AUGUST 24, 2012, THE CME INITIATED AN ACTION BEFORE THE CBOT BUSINESS CONDUCT COMMITTEE ("BCC") BASED ON THE VIOLATION THAT OCCURRED IN OCTOBER 2010, SEEKING PENALTIES AND DISGORGEMENT OF APPROXIMATELY $350,000 IN PROFITS RESULTING FROM THE EXCESS POSITION. THE OCTOBER 2010 VIOLATION INVOLVED AN UNINTENTIONAL OVERAGE OF APPROXIMATELY 7%, WHICH WAS CORRECTED WITHIN APPROXIMATELY THREE REGULAR TRADING HOURS. FORTRESS CHOSE TO DEFEND THE ACTION RATHER THAN SETTLING IT, ARGUING THAT, BASED ON APPLICABLE RULES, THE APPROPRIATE SANCTION WAS ONLY A WARNING LETTER. THIS WAS FORTRESS' FIRST EVER VIOLATION OF ANY CBOT, CME OR CFTC RULE. PRIOR TO THE VIOLATION, FORTRESS WAS IN THE PROCESS OF IMPLEMENTING AN AUTOMATED SYSTEM TO MONITOR APPLICABLE LIMITS ACROSS CLIENT ACCOUNTS. SHORTLY AFTER THE VIOLATION, FORTRESS COMPLETED THE IMPLEMENTATION, AND THERE HAVE BEEN NO SUBSEQUENT POSITION LIMIT VIOLATIONS. ON NOVEMBER 27, 2012, FORTRESS APPEARED BEFORE THE BCC IN A CONTESTED HEARING AND WAS FINED $90,000 AND ORDERED TO PAY DISGORGEMENT OF APPROXIMATELY $350,000. ON JANUARY 28, 2013, FORTRESS APPEALED THE BCC RULING, AND THE APPELLATE PANEL OF THE CME AFFIRMED THE BCC DECISION ON JUNE 19, 2013.

Allegations: FIG LLC DID NOT TIMELY FILE TWO INITIAL SCHEDULE 13D DISCLOSURES, ONE FORM 3 DISCLOSURE, AND ONE SCHEDULE 13D AMENDMENT DISCLOSURE. Status: Final Sanction Detail: THE ORDER IS FINAL AND THE PENALTY WAS PAID IN FULL TO THE SEC ON SEPTEMBER 30, 2024. Summary: ON SEPTEMBER 25, 2024, THE SEC PUBLISHED AN ADMINISTRATIVE ORDER OF SETTLEMENT BETWEEN IT AND FIG LLC (THE "ORDER") IN WHICH THE FIRM NEITHER ADMITTED NOR DENIED THE FINDINGS RELATED TO THE TIMELINESS OF THREE SCHEDULE 13D FILINGS AND ONE FORM 3 FILING. THE FIRM CONSENTED TO THE ENTRY OF THE SETTLED ADMINISTRATIVE ORDER FINDING VIOLATIONS OF SECTION 13(D)(1), 13(D)(2), AND 16(A) OF THE EXCHANGE ACT AND RULES 13D-1, 13D-2, AND 16A-3 THEREUNDER, AND WAS ORDERED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF SECTION 13(D)(1), 13(D)(2), AND 16(A) OF THE EXCHANGE ACT AND RULES 13D-1, 13D-2, AND 16A-3 THEREUNDER AND PAY A CIVIL MONETARY PENALTY OF $200,000.