Notice of Disciplinary Action

FILE NO.:                   21-CH-2101

MEMBER FIRM:         Citigroup Global Markets Inc.        

CBOT Rules:              930.E. Calls for Performance Bond

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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.

                                 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:

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4.  Completely and accurately computing and recording the balances in the net capital computation including capital requirements;

                              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:

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  2. Computing, recording and reporting completely and accurately the balances in the:          

  a. Statement of Segregation Requirements and Funds in Segregation;

  b. Statement of Secured Amounts and Funds Held in Separate Accounts; and

  c. Statement of Segregation Requirements and Cleared Swaps Customer Collateral Held in    Cleared Swaps Customer Accounts. 

                              980. FINANCIAL RECORDS AND REPORTS

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B.      Each clearing member shall maintain an adequate accounting system, internal accounting controls, and procedures for safeguarding customer and firm assets. This includes, but is not limited to, the following:

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2.  Resolution computing and recording the balances in the net capital computation including capital requirements;                                              

FINDINGS:                 Pursuant to an offer of settlement in which Citigroup Global Markets Inc. neither admitted nor denied the rule violations upon which the penalty is based, on March 18, 2021, the Clearing House Risk Committee found that Citigroup Global Markets Inc. violated CBOT Rules 930.E.2., 970.A.4., 971.A.2.a. b. and c. and 980.B.2.

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

EFFECTIVE DATE:    March 19, 2021