NOTICE OF SUMMARY ACTION

FILE NO.:

CME-RSRH-18-5285

MEMBER FIRM:

R.J. O’BRIEN & ASSOCIATES, LLC

CME RULE:

854.C. CONCURRENT LONG AND SHORT POSITIONS (in part)

Set forth below are the procedures that must be followed for concurrent long and short positions and hold-open accounts…

C. Clearing members which, pursuant to this rule, carry concurrent long and short positions, must report to the Exchange both sides as open positions. When either side or both sides are reduced, the open positions as reported to the Exchange must be reduced accordingly, and, pursuant to Rule 806, may not subsequently be re-opened at the Exchange.

811. POSITION CHANGE DATA

Position change data must be submitted to the Clearing House each trading day not later than the time specified by the Clearing House. Position change data will be in such form and contain such information as prescribed by the Clearing House. When requested, the identification of accounts will be made available to the Financial and Regulatory Surveillance Department.

FINDINGS:

In several instances during the month of October 2018, R.J. O’Brien & Associates, LLC inaccurately reported its open interest in various Chicago Mercantile Exchange in violation of Rule 854.C. and 811.

PENALTY:

On November 8, 2018, the Rule 512 Committee, pursuant to Rule 512, assessed a fine in the amount of $2,500 against R.J. O’Brien & Associates, LLC for its violations of Rule 854.C. and 811, as follows:

EFFECTIVE DATE:

November 29, 2018