NOTICE OF DISCIPLINARY ACTION

FILE NO.:                   19-CH-1905

MEMBER FIRM:         R.J. O’Brien & Associates, LLC

CME Rule:                  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 R.J. O’Brien & Associates, LLC neither admitted nor denied the rule violation upon which the penalty is based, on November 21, 2019, the Clearing House Risk Committee found that R.J. O’Brien & Associates, LLC violated CME Rule 971.A.1.

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

EFFECTIVE DATE:    November 22, 2019