NOTICE OF SUMMARY ACTION

FILE NO:

CBOT RSRH-23-7104-2

MEMBER FIRM:

R.J. O’Brien & Associates LLC

RULE VIOLATION:

561. REPORTS OF LARGE POSITIONS (in pertinent part)

Clearing members, omnibus accounts and foreign brokers shall submit to the Exchange a daily report of all positions required to be reported as set forth in the Position Limit, Position Accountability and Reportable Level Table in the Interpretations Section at the end of Chapter 5.  Positions at or above the reportable level in a particular expiration month of a futures contract, or in all puts or in all calls of a particular option contract expiration month, are required to be reported. For an account with reportable positions in a particular contract, all positions, regardless of size, in any contract month and in any contract that aggregates with that contract must be reported… 

The Exchange may require that more than one large trader position report be electronically submitted daily.  The Business Conduct Committee or the Market Regulation Department may require reports or additional account identification from any clearing member, omnibus account or foreign broker on a lesser number of positions than reflected in the Position Limit, Position Accountability and Reportable Level Table.

FINDINGS:

During the month of November 2023, R.J. O’Brien & Associates LLC did not submit large trader adjustments within the prescribed deadline, and Forms 102A were not updated within the 3-business day requirement of material changes becoming effective, in violation of Rule 561. 

PENALTY:

On December 13, 2023, pursuant to Rule 512, a fine in the amount of $1,000 was assessed against R.J. O’Brien & Associates LLC for its violations of Rule 561.

EFFECTIVE DATE:

January 2, 2024