NOTICE OF DISCIPLINARY ACTION

Board of Trade of the City of Chicago, Inc.

NOTICE OF DISCIPLINARY ACTION

FILE NO.:                   21-CH-2106

MEMBER FIRM:         ABN AMRO Clearing Chicago LLC

CBOT Rules:              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:

1.     Maintenance of minimum capital requirements of at least $5 million except that a clearing member that is a bank must maintain minimum Tier I Capital (as defined in accordance with regulation applicable to the relevant bank) of at least $5 billion:

*****

980. REQUIRED RECORDS AND REPORTS

*****

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:

3. Prevention of a material inadequacy as defined in CFTC Regulation 1.16(d)(2).                                               

FINDINGS:                 Pursuant to an offer of settlement in which ABN AMRO Clearing Chicago LLC neither admitted nor denied the rule violations upon which the penalty is based, on June 10, 2021, the Clearing House Risk Committee found that ABN AMRO Clearing Chicago LLC violated CBOT Rules 970.A.1. and 980.B.3.

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

EFFECTIVE DATE:    June 11, 2021