NOTICE OF SUMMARY ACTION

FILE NO.:

DQA - 19-0003

MEMBER FIRM:

NOMURA SECURITIES INTERNATIONAL, INC

RULE VIOLATION:

Rule 536.B.2 Electronic Audit Trail Requirements for Electronic Order Routing/Front-End Systems

Entities certified by the Exchange to connect an order routing/front-end system to the Globex platform through the CME iLink® gateway are responsible for creating an audit trail of each message entered into Globex. Clearing members guaranteeing a connection to Globex are responsible for maintaining or causing to be maintained the electronic audit trail for such systems. This electronic audit trail must be maintained for a minimum of 5 years, and clearing members must have the ability to produce this data in a standard format upon request of Market Regulation.

Each such electronic audit trail must be complete and accurate and account for every electronic communication such system receives or generates, including any electronic communication such system receives from Globex.

FINDINGS:

During the electronic audit trail review, Nomura Securities International, INC self-reported missing audit trail data for 9 unique calendar dates spanning October through November 2018. Nomura failed to maintain a complete electronic audit trail for a minimum of 5 years and was therefore in violation of Rule 536.B.2 ("Globex Order Entry – Electronic Audit Trail Requirements for Electronic Order Routing/Front-End Systems").

PENALTY:

On July 31, 2019, Nomura Securities International, INC, pursuant to Rule 512 (“Reporting Infractions”) was issued a $1000 fine by the 512 committee for its violation of Rule 536.B.2.

EFFECTIVE DATE:

August 19, 2019