CBOE Futures Exchange brought two actions in November 2016 against trading privilege holders who allegedly placed orders in the CBOE Volatility Index Trade at Settlement futures that were rejected by the exchange for being placed pre-market open, when the firms knew or should have known such orders would be rejected. In one action, Virtu Financial settled charges against it by agreeing to pay a fine of US $25,000 for “several occasions” in 2015; in another action, Locust Walk Trading LLC agreed to pay a penalty of US $15,000 for the same offense for “several occasions” between May and August 2015. Separately, Sumo Capital LLC, also a trading privilege holder, agreed to pay a fine of US $40,000 for not providing required audit trail records to the exchange or being able to show such records were maintained as required by exchange rule for the period November 2013 through August 2015.