CFTC v. SummerHaven Investment Management LLC (wash trading, 2021)
Judgment entered
Checked against the primary document on October 2, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.
In May 2021, the CFTC settled charges against Connecticut commodity trading advisor SummerHaven Investment Management LLC, ordering a US$500,000 penalty for wash sales and noncompetitive trades made while moving a client's futures positions between two brokers.
The record
| Agency | CFTC |
|---|---|
| Release number | 8389-21 |
| Date filed | 2021-05-18 |
| Date resolved | 2021-05-18 |
| Status | judgment |
| Asset class | commodities |
| Venue | CME |
| Criminal parallel | No |
| Defendants | SummerHaven Investment Management LLC |
| Techniques | Wash trading |
What was ordered
- Civil penalty
- $500k
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $500k
- Alleged gain
- —
What is alleged to have happened
The Commodity Futures Trading Commission announced this matter on May 18, 2021 as release 8389-21. The respondents named are SummerHaven Investment Management LLC (0 individuals, 1 entity).
The order finds that on July 2, 2018, SummerHaven placed offsetting buy and sell orders at each of two futures commission merchants to move a client's positions, producing over 100 prearranged offsetting trades worth more than $570 million across crude oil, heating oil, gasoil, cattle, hogs, soybean meal, gasoline, cocoa and cotton. Both sides belonged to the same client, so this is a wash sale, not a matched order. SummerHaven also had no procedures to prevent such trades, and its then-chief compliance officer and managing partner reviewed and directed the decision.
This library tags the matter as wash trading, based on the conduct the regulator describes. Each tag links to a page explaining how that technique works, what statute it engages, and what penalties comparable actions have attracted. The tagging is ours, not the regulator's: agencies charge statutory provisions, not technique names.
A $500,000 civil monetary penalty and a cease-and-desist order.
SummerHaven consented to the order.
What technique is this, and how does it work?
This action is tagged with one technique in our taxonomy. The tagging is ours: regulators charge statutory provisions, not technique names, so the mapping is an editorial judgement described in our editorial policy.
- Wash trading — see how it works, what statute it engages, and every other action tagged the same way.
Timeline
- 2021-05-18 CFTC release published
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.
Related actions
Other actions in the library sharing at least one technique tag with this one.