CBOT-RSRH-23-6886-GOLDMAN-SACHS-AND-CO

FILE NO.:             

CBOT RSRH-23-6886

MEMBER FIRM:

Goldman Sachs & Co.  

CBOT RULE VIOLATION:

526.F. BLOCK TRADES

Unless otherwise agreed to by the principal counterparties to the block trade, the seller, or, in the case of a brokered transaction, the broker handling the block trade, must ensure that each block trade is reported to the Exchange within the time period and in the manner specified by the Exchange. The report must include the contract, contract month, price, quantity of the transaction, the respective clearing members, the time of execution, and, for options, strike price, put or call and expiration month. The Exchange shall promptly publish such information separately from the reports of transactions in the regular market.

MRAN RA-2204-5 (in part)

The failure to submit timely, accurate and complete block trade reports may subject the party responsible for the reporting obligation to disciplinary action.

FINDINGS:         

On 41 occasions between January 2022 and March 2023, Goldman Sachs & Co. submitted proprietary block trades under an account designated for customer orders, thus submitting inaccurate block trade reports to the Exchange. These block trades were executed in September 2022 and December 2022 U.S. Treasury Bond Futures, March 2022, June 2022, and September 2022 10-Year T-Note Futures, March 2022, June 2022, September 2022, and December 2022 5-Year T-Note Futures, March 2022, June 2022, and September 2022 2-Year T-Note Futures, and August 2022 and April 2023 30 Day Federal Funds Futures.  

PENALTY:

On June 28, 2023, pursuant to Rule 512, a fine in the amount of $4,000 was assessed against Goldman Sachs & Co. for its violations of CBOT Rule 526 and CBOT Rule 526.F.

EFFECTIVE DATE:

July 21, 2023