• NOTICE OF DISCIPLINARY ACTION

      • #
      • 17-CH-1706
      • Notice Date
      • 29 September 2017
      • Effective Date
      • 29 September 2017
    • FILE NO.:                     17-CH-1706                              

      MEMBER FIRM:           SG Americas Securities LLC

      CME RULES:              

        970. FINANCIAL REQUIREMENTS

      A. Subject to exemptions granted by Exchange staff, all clearing members including non-FCMs, must comply with the requirements set for the in CFTC Regulations 1.10, 1.12, 1.17 and 1.18. This includes, but is not limited to, the following:

      4. Completely and accurately computing and recording the balances in the net        

          capital computation including requirements;

      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;

      b. Statement of Secured Amounts and Funds Held in Separate

          Accounts; and

      c. Statement of Segregation Requirements and Cleared Swaps

          Customer Collateral Held in Cleared Swaps Customer Accounts.

      980. REQUIRED RECORDS AND REPORTS

      A. Each clearing member shall prepare, maintain and keep current those books and records required by the rules of the Exchange, the Commodity Exchange Act and the Regulations thereunder. Such books and records shall be open to inspection and promptly provided to the Exchange upon request.

      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;

      FINDINGS:                    Pursuant to an offer of settlement in which SG Americas Securities LLC neither admitted nor denied the rule violations upon which the penalty is based, on September 28, 2017, the Clearing House Risk Committee found that SG Americas Securities LLC violated CME Rules 970.A.4, 971.A.2.a., b. and c., 980.A. and 980.B.1. and 2. 

      PENALTY:                    In accordance with the settlement offer, the Clearing House Risk Committee imposed a $150,000 fine.

      EFFECTIVE DATE:       September 29, 2017