NOTICE OF DISCIPLINARY ACTION

Board of Trade of the City of Chicago, Inc.

NOTICE OF DISCIPLINARY ACTION

FILE NO.:                   20-CH-2006

MEMBER FIRM:         BNP Paribas Securities Corp.        

CBOT Rules:              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;

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 preapproved 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 BNP Paribas Securities Corp.  neither admitted nor denied the rule violations upon which the penalty is based, on August 20, 2020, the Clearing House Risk Committee found that BNP Paribas Securities Corp. violated CBOT Rules 971.A.1. and 971.E.

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

EFFECTIVE DATE:    August 21, 2020