NOTICE OF SUMMARY ACTION

FILE NO.:

CME 20-0532 CTRA

MEMBER:

R.J. O’BRIEN & ASSOCIATES LLC

RULE VIOLATION:

536.  RECORDKEEPING REQUIREMENTS FOR PIT, GLOBEX AND NEGOTIATED TRADES

F.  CTR Enforcement Program and Sanction Schedule

(In pertinent part)

The Market Regulation Department will conduct audits of clearing members in order to verify the accurate recording and submitting of required audit trail information.

FINDINGS:   

Pursuant to the results of a back office CTR audit, on September 3 through October 8, 2020, R.J. O’Brien & Associates LLC was found to be in violation of the CTR data entry error by exceeding the 10% error level mandated by Rule 536.F.

PENALTY:

Pursuant to the Rule 536.F sanction schedule, R.J. O’Brien & Associates LLC. was issued a $2,500 fine on January 7, 2021 for its first violation of Rule 536.F. within 24 months.

EFFECTIVE DATE:

January 26, 2021