NOTICE OF SUMMARY ACTION

FILE NO.:

CBOT 19-0028

MEMBER FIRM:

GOLDMAN, SACHS & CO.

RULE VIOLATION:

Rule 536.B.2 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:

Goldman, Sachs & Co. failed to maintain a complete electronic audit trail for certain dates ranging from August 2015 and ending in October 2016.

PENALTY:

On September 11, 2019 pursuant to Rule 512, a fine in the amount of $2,000 was assessed against Goldman, Sachs & Co. Inc. for its violation of CBOT Rule 536.B.2.