The Commodity Futures Trading Commission filed and settled charges against Credit Suisse International for allegedly violating an augmented speculative position limit for wheat futures on several days in April and June 2009. The CFTC also filed and settled charges against Credit Suisse Securities (USA) LLC for purportedly filing certain false information with the CFTC related to the purpose of CSI’s wheat futures positions. In total, the two Credit Suisse entities agreed to pay a fine of US $665,000 to resolve the CFTC’s charges, including US $140,000 by CSS for its specific alleged violation. According to the CFTC, in September 2008, CSS requested the CFTC to grant CSI a hedge exemption to the Commission’s then prevailing 6500 contracts all-months speculative position limit in wheat futures. This request apparently was made to accommodate the firms’ clients that were liquidating commodity swap positions with certain counterparties experiencing financial difficulties during the 2008-2009 financial crisis, and re-establishing such position with CSI. The CFTC claimed that, despite granting CSS’s request for CSI, on several days during the relevant time CSI still exceeded its enhanced position limit. Subsequently, in March 2013, CSS, on behalf of CSS, submitted information to the CFTC that the agency alleged was different from information the firm contemporaneously provided the CFTC in 2009. The new information purportedly showed that CSI’s hedge exemption “would have been higher in April and June 2009 than was warranted by information submitted to the Commission in 2009.” Based on the new information, CSI would not have violated its augmented position limit at the relevant time. However, the CFTC claimed that new information was “materially false or misleading” by including inflated swaps information. Applicable law prohibits a person from making “any false or misleading statement of a material fact” to the CFTC. (Click here to access Section 6(c)(2) of the Commodity Exchange Act (see 7 U.S. Code §9(2).)