Summerhaven Investment Management, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed
in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CME GROUP, INC., MARKET REGULATION DEPARTMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/06/2015
 Exact
 Explanation
If not exact, provide explanation:
THIS IS THE DATE ON WHICH SUMMERHAVEN INVESTMENT MANAGEMENT, LLC RECEIVED A NOTICE OF ENFORCEMENT FROM THE MARKET REGULATION
DEPARTMENT OF CME GROUP INC.
4.
Docket/Case Number:
NYMEX 14-0062-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EXCHANGE FOR RELATED POSITIONS TRANSACTION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JUNE 2, 2014, SUMMERHAVEN INVESTMENT MANAGEMENT, LLC ("SUMMERHAVEN") ENTERED INTO AN EXCHANGE FOR RELATED POSITIONS
TRANSACTION. THE MARKET REGULATION DEPARTMENT OF CME GROUP INC. ALLEGED THAT SUMMERHAVEN DID NOT PROPERLY MAINTAIN
DOCUMENTATION OF THE CORRESPONDING, SIMULTANEOUS SWAP TRANSACTION, AND THEREFORE VIOLATED NYMEX RULE 538.H.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
04/15/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 7,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,

Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
ON MARCH 24, 2015, SUMMERHAVEN INVESTMENT MANAGEMENT, LLC ("SUMMERHAVEN") SUBMITTED AN OFFER OF SETTLEMENT TO THE NEW YORK
MERCANTILE EXCHANGE BUSINESS CONDUCT COMMITTEE (THE "BCC") IN WHICH SUMMERHAVEN NEITHER ADMITTED NOR DENIED THE ALLEGED
VIOLATION OF NYMEX RULE 538.H. ON APRIL 15, 2015, SUMMERHAVEN PRESENTED THE OFFER OF SETTLEMENT TO A PANEL OF THE BCC, WHICH
WAS SUPPORTED BY THE MARKET REGULATION DEPARTMENT. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE BCC ORDERED SUMMERHAVEN
TO PAY A FINE OF $7,500 TO THE NEW YORK MERCANTILE EXCHANGE. SUMMERHAVEN PAID THE FINE ON APRIL 17, 2015 AND THE MATTER IS NOW
CLOSED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must
fit within the space provided).
ON MARCH 24, 2015, SUMMERHAVEN INVESTMENT MANAGEMENT, LLC ("SUMMERHAVEN") SUBMITTED AN OFFER OF SETTLEMENT TO THE NEW YORK
MERCANTILE EXCHANGE BUSINESS CONDUCT COMMITTEE (THE "BCC") IN WHICH SUMMERHAVEN NEITHER ADMITTED NOR DENIED THE ALLEGED
VIOLATION OF NYMEX RULE 538.H. ON APRIL 15, 2015, SUMMERHAVEN PRESENTED THE OFFER OF SETTLEMENT TO A PANEL OF THE BCC, WHICH WAS
SUPPORTED BY THE MARKET REGULATION DEPARTMENT. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE BCC ORDERED SUMMERHAVEN TO PAY A
FINE OF $7,500 TO THE NEW YORK MERCANTILE EXCHANGE. SUMMERHAVEN PAID THE FINE ON APRIL 17, 2015 AND THE MATTER IS NOW CLOSED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4),
and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed
in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the
IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
COMMODITY FUTURES TRADING COMMISSION ("CFTC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST
3.
Date Initiated (MM/DD/YYYY): 
06/15/2021
 Exact
 Explanation
If not exact, provide explanation:
IN OR ABOUT JUNE 2018 TO IN OR ABOUT JULY 2018
4.
Docket/Case Number:
CFTC DOCKET NO. 21-7
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CFTC ISSUED AN ORDER (THE "ORDER") FINDING THAT FROM ON OR ABOUT JUNE 2018 TO ON OR ABOUT JULY 2018, SUMMERHAVEN (A) ENTERED
BIDS AND OFFERS FOR THE SAME QUANTITIES OF THE SAME FUTURES CONTRACTS FOR TRADING ACCOUNTS THAT HAD THE SAME BENEFICIAL OWNER AND
WHICH WERE INTENDED TO AND DID IN FACT OFFSET EACH OTHER UPON EXECUTION (I.E., "WASH SALES") IN VIOLATION OF SECTION 4C(A)(L) AND (2)
(A) OF THE COMMODITY EXCHANGE ACT (THE "ACT") AND CFTC REGULATION 1.38(A) AND (B) IN CONNECTION WITH THE ALLEGED WASH SALES, FAILED
TO SUPERVISE ITS ACTIVITIES IN VIOLATION OF CFTC REGULATION 166.3.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
05/18/2021
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of
penalty was waived: 
SEE DESCRIPTION IN ITEM 13 BELOW.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must

fit within the space provided).
SUMMERHAVEN SUBMITTED, AND THE CFTC ACCEPTED, AN OFFER OF SETTLEMENT IN WHICH IT, WITHOUT ADMITTING OR DENYING ANY OF THE CFTC'S
FINDINGS. AGREED (A) TO CEASE AND DESIST FROM VIOLATING SECTION 4C(A)(L) AND (2)(A) OF THE ACT AND CFTC REGULATIONS 1.38(A) AND 166.3
AND (B) TO PAY A SUMMERHAVEN SHALL PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF FIVE HUNDRED THOUSAND DOLLARS ($500,000.00) ("CMP
OBLIGATION"), PLUS ANY POST-JUDGMENT INTEREST. SUMMERHAVEN SHALL SATISFY THE CMP OBLIGATION BY MAKING PAYMENTS AS FOLLOWS: -
$100,000 TO BE PAID WITHIN 10 DAYS OF ENTRY OF THE ORDER; - $200,000 TO BE PAID WITHIN 12 MONTHS OF THE DATE OF ENTRY OF THE ORDER; AND
- $200,000 TO BE PAID WITHIN 24 MONTHS OF THE DATE OF ENTRY OF THE ORDER. POST-JUDGMENT INTEREST SHALL ACCRUE ON THE CMP OBLIGATION
BEGINNING ON THE DATE OF ENTRY OF THE ORDER AND SHALL BE DETERMINED BY USING THE TREASURY BILL RATE PREVAILING ON THE DATE OF ENTRY.
THE FORMER MANAGING PARTNER/HEAD OF TRADING AND THE FORMER PARTNER/CHIEF COMPLIANCE OFFICER IDENTIFIED IN THE ORDER IN
CONNECTION WITH THE EXECUTION, SUPERVISION AND APPROVAL OF THE ALLEGED WASH TRADES ARE NO LONGER EMPLOYED AT SUMMERHAVEN AS OF
DECEMBER 2019.