NOTICE OF SUMMARY ACTION

FILE NO.:                   

20-0292                      

MEMBER FIRM:                         

MAKO GLOBAL DERIVATIVES PARTNERSHIP LLP

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:                 

Mako Global Derivatives Partnership LLP failed to maintain a complete electronic audit trail for the timeframe of April 1, 2016 through February 26, 2017.

PENALTY:                 

On April 22, 2020, pursuant to Rule 512 (“Reporting Infractions”), Mako Global Derivatives Partnership LLP was issued  a $1,000 fine for its violation of Rule 536.B.2.                                  

EFFECTIVE DATE:                        

May 19, 2020