NOTICE OF SUMMARY ACTION

FILE NO:

CME DQA‐23-1153

MEMBER FIRM:

Jefferies LLC

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:

Jefferies LLC failed to maintain a complete electronic audit trail for dates between November 13, 2019, and September 28, 2020.

PENALTY:

On March 22, 2023, Jefferies LLC, pursuant to Rule 512 (“Reporting Infractions”), was collectively issued a $4,000 fine for its violations of Rule 536.B.2 as follows (see companion case CBOT DQA-23-1153):  CBOT - $2,000; CME - $2,000.

EFFECTIVE DATE:

April 10, 2023