NOTICE OF DISCIPLINARY ACTION

MEMBER:

R.J. O’Brien & Associates, LLC

CBOT RULE VIOLATION:

Rule 432        General Offenses

It shall be an offense:

W.        for a Member to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

FINDINGS:

Pursuant to an offer of settlement in which R.J. O’Brien & Associates, LLC (“RJO”) neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on August 4, 2020, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that between June 1, 2017, and June 6, 2018, RJO failed to diligently supervise its employee and futures broker who traded his personal trading account opposite RJO’s customers’ orders he worked in the Treasury Options pit. Specifically, RJO failed to adequately monitor the employee’s personal trading account despite permitting the employee to trade the personal account while working customer orders. Although RJO conducted an internal investigation, RJO failed to detect the employee trading opposite customer orders for one year, both before and after the internal investigation.

The Panel found that as a result of the foregoing, RJO violated CBOT Rule 432.W.

PENALTY:

In accordance with the settlement offer, the Panel ordered RJO to pay a fine of $150,000.

EFFECTIVE DATE:

August 6, 2020