NOTICE OF SUMMARY ACTION

FILE NO:

CME DQA‐22-1005

MEMBER FIRM:

BNP PARIBAS SECURITIES CORP.

RULE VIOLATION:

Rule 536.B.2 ("Globex Order Entry - 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:

BNP Paribas Securities Corp. failed to maintain a complete electronic audit trail for certain dates in January 2022 and March 2022.

PENALTY:

On November 2, 2022, BNP Paribas Securities Corp, pursuant to Rule 512 (“Reporting Infractions”), was issued a $1,000 fine for its violations of Rule 536.B.2

EFFECTIVE DATE:

November 21, 2022