NOTICE OF DISCIPLINARY ACTION

FILE NO.:                     18-CH-1802                  

MEMBER FIRM:           ABN AMRO Clearing Chicago LLC

CBOT RULES:              970.    FINANCIAL REQUIREMENTS

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

1.         Maintenance of minimum capital requirements of at least $5 million except that a clearing member that is a bank must maintain minimum Tier I Capital (as defined in accordance with regulation applicable to the relevant bank) of at least $5 billion;

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:

1.         Maintaining sufficient funds at all times in segregation, secured 30.7 and Cleared Swaps Customer accounts;                

FINDINGS:                Pursuant to an offer of settlement in which ABN AMRO Clearing
Chicago LLC neither admitted nor denied the rule violations upon which the penalty is based, on June 28, 2018, the Clearing House Risk Committee found that ABN AMRO Clearing Chicago LLC violated CBOT Rules 970.A.1. and 971.A.1.  

PENALTY:                  In accordance with the settlement offer, the Clearing House Risk Committee imposed a $50,000 fine.

EFFECTIVE DATE:       June 29, 2018