NOTICE OF DISCIPLINARY ACTION

FILE NO.:                   20-CH-2001

MEMBER FIRM:         BofA Securities, Inc.

CBOT Rules:               971. SEGREGATION, SECURED AND CLEARED SWAPS CUSTOMER ACCOUNT REQUIREMENTS

E.     All disbursements not made for the benefit of a customer from a segregated, secured 30.7 or Cleared Swaps Customer account which exceed 25% of the FCM clearing members excess segregated, secured 30.7 or Cleared Swaps Customer of the respective origin must be pre-approved in writing by the clearing member’s Chief Executive Officer, Chief Financial Officer or their authorized representative with knowledge of the firm’s financial requirements and position.

FINDINGS:                 Pursuant to an offer of settlement in which BofA Securities, Inc. neither admitted nor denied the rule violation upon which the penalty is based, on June 11, 2020, the Clearing House Risk Committee found that BofA Securities, Inc. violated CBOT Rule 971.E.

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

EFFECTIVE DATE:    June 12, 2020