CHICAGO MERCANTILE EXCHANGE
NOTICE OF DISCIPLINARY ACTION
FILE NO.: 14-CH-1410
MEMBER FIRM: Timber Hill LLC
971. SEGREGATION, SECURED AND CLEARED SWAPS CUSTOMER ACCOUNT REQUIREMENTS
A. All clearing members must comply with the requirements set forth in CFTC Regulations 1.20 through 1.30, 1.32, 1.49 and 30.7, and Part 22 of the CFTC Regulations. This includes, but is not limited to, the following:
2. Computing, recording and reporting completely and accurately the balances in the:
a. Statement of Segregation Requirements and Funds in Segregation;
980. REQUIRED RECORDS AND REPORTS
B. Each clearing member shall maintain an adequate accounting system, internal accounting controls, and procedures for safeguarding customer and firm assets. This includes, but is not limited to, the following:
1. Preparation and maintenance of complete and accurate reconciliations for all accounts;
2. Resolution of reconciling items in a timely manner; and
3. Prevention of a material inadequacy as defined in CFTC Regulation 1.16(d)(2).
FINDINGS: Pursuant to an offer of settlement in which Timber Hill LLC neither admitted nor denied the rule violations upon which the penalty is based, on October 23, 2014, the Clearing House Risk Committee found that Timber Hill LLC violated CME Rules 971.A.2. and 980.B.
PENALTY: In accordance with the settlement offer, the Clearing House Risk Committee fined Timber Hill LLC $25,000.
EFFECTIVE DATE: October 24, 2014
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