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Recordkeeping Requirements for Open Auction Trading

Members are reminded that in accordance with CBOT Regulations 332.07, Accountability of Trading Documents, and 545.02, Record Keeping, as well as applicable CFTC regulations, all documents on which original trade information is recorded in writing must be retained for five years.

Members should review their record retention procedures and ensure compliance with the following:

Members Utilizing EC (Electronic Clerk) Devices
Members who utilize an EC are reminded that any documents, including brokerage cards or mock order tickets, on which original execution information is recorded, must be retained for five years.

Members Recording Executions on Brokerage Cards
Members who use brokerage cards to record original order execution information must retain the original brokerage cards for five years.

Members Utilizing HHT (Hand Held Technology) Devices
Members who record their trades on trading cards and subsequently have the data entered into a handheld device must ensure that the trading cards, which represent the original record of the transactions, are retained for five years.

Members are responsible for arranging for the storage of any such documents that are not otherwise maintained by the respective clearing firm and must be able to promptly produce such documents upon request. Documents created within the past year must, upon request, be produced within five business days, and documents created more than a year ago must be produced within ten business days.

Failure to adhere to these document retention requirements may result in disciplinary action by the Exchange.

Questions regarding this notice may be directed to Jennifer Baum (312-341-3124) or Shelly Goodwin (312-347-4123) of the Office of Investigations and Audits.

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