NOTICE OF SUMMARY ACTION

FILE NO:

CME DQA‐23-1214

MEMBER FIRM:

BNP PARIBAS SECURITIES CORP

RULE VIOLATION:

Rule 536.C. BUNCHED ORDERS AND ORDERS ELIGIBLE FOR POST EXECUTION ALLOCATION

Bunched orders must be allocated and recorded in accordance with CFTC Regulation 1.35(b) and the NFA’s Interpretive Notice related to Compliance Rule 2-10. With respect to bunched Globex orders, such orders may be entered using a series designation or suspense account number provided that 1) the order is being placed by an eligible account manager for multiple accounts eligible for post execution allocation or 2) a written, pre-determined allocation scheme that defines the series has been provided to the futures commission merchant accepting or clearing the order prior to the time that such order is entered. In the latter case, if such information has not been provided to the futures commission merchant prior to the time of order entry, each specific account number must be entered into Globex. Additionally, for all such bunched orders executed on Globex, the final account specific allocations must be submitted to the clearing system no later than the end of each trading day.

FINDINGS:

During the period of January 1, 2023 to March 31, 2023, BNP Paribas Securities Corp. violated Rule 536.C by entering customer orders in a suspense account designated for proprietary order flow.

PENALTY:

On July 26, 2023, BNP Paribas Securities Corp, pursuant to Rule 512 (“Reporting Infractions”), was issued a $4,000 for its violations of Rule 536.C. 

EFFECTIVE DATE:

August 11, 2023