NOTICE of DISCIPLINARY ACTION

FILE NO.:                     18-CH-1805                              

MEMBER FIRM:           Credit Suisse Securities (USA) LLC

CBOT RULES:             930. PERFORMANCE BOND REQUIREMENTS: ACCOUNT HOLDER LEVEL

D. Acceptance of Orders

Clearing members may accept orders for an account provided sufficient performance bond is on deposit in the account or is forthcoming within a reasonable time.

For an account which has been subject to calls for performance bond for an unreasonable time, clearing members may only accept orders that reduce the performance bond requirements of existing positions in the account.

Clearing members may not accept orders for an account that has been in debit an unreasonable time

E.  Calls for Performance Bond

2.    Clearing members shall only reduce a call for performance bond through    the receipt of performance bond deposits permitted under subsection C. of this rule. Clearing members may cancel a call for performance bond through: a) the receipt of performance bond deposits permitted under subsection C. of this rule only if such deposits equal or exceed the amount of the total performance bond call; or b) inter-day favorable market movements and/or the liquidation of positions only if performance bond equity in the account is equal to or greater than the initial performance bond requirement. Clearing members shall reduce an account holder's oldest outstanding performance bond call first.

3.     Clearing members must maintain written records of all performance bond calls issued and satisfied in whole or in part.

F. Release of Excess Performance Bond

Subject to exceptions granted by Exchange staff, clearing members may only release performance bond deposits from an account if such deposits are in excess of initial performance bond requirements.

FINDINGS:                    Pursuant to an offer of settlement in which Credit Suisse Securities (USA) LLC neither admitted nor denied the rule violations upon which the penalty is based, on August 23, 2018, the Clearing House Risk Committee found that Credit Suisse Securities (USA) LLC violated CBOT Rules 930.D., 930.E.2., 930.E.3. and 930.F.

PENALTY:                    In accordance with the settlement offer, the Clearing House Risk Committee imposed a $100,000 fine.

EFFECTIVE DATE:       August 24, 2018