The CTR Monthly Enforcement Program provides members with an opportunity to present evidence of data input errors in order to have warning and fine letters rescinded.  Recently, Market Regulation received documentation submitted on behalf of a member which purported to show that the recorded bracket on the floor order or attached trading card was not correctly keypunched by firm personnel.  Further inquiry revealed that the original recorded bracket may have been changed.

Clearing member firms are reminded that they are responsible for the security of floor order tickets and are liable for any misuse of them. Brackets which are changed on original orders for the purpose of having bracket fines or warning letters rescinded is a violation of CME rules and the firm could have potential liability for allowing access to floor orders for which it has retention responsibilities under CFTC regulations and CME rules.

Members should ensure that clerks who are employed to handle rescission requests for CTR fines and warning letters are made aware of this advisory.  If you have any questions about this advisory or the CTR Enforcement Program, please call David Peloquin, Investigator, at (312) 648-5415 or Louvin Abarcar, Associate Director, Market Regulation, at (312) 648-3623.