07/09/2001
As incentive, any member attending any one class will be allowed to "do over" up to two subsequent months in which their trade time rates are between 70% and 79%. The mem-ber will still have to complete four violation-free months before his record is "cleared out" but he may take up to six months to do so. Members may take one class per year.
Audit Trail Classes
· Purpose: to improve pit card submission statistics Exchange-wide by reducing the number of individual members falling below the 80% standard for timely pit card submission and to facilitate their return to a "warning letter" level.
· Members who have received a warning letter or a fine for pit card violations may:
- Attend one audit trail class, to be offered on July 10, and August 15, 2001, with future dates to be determined by the Floor Committee/Compliance Review Committee. The class will be an intensive discussion of pit card problems and pitfalls. Materials will focus on how the audit trail works and successful strategies for achieving a passing percentage. Members will be required to analyze their own trading style in light of the material presented and pinpoint areas in which they need to improve. Members will also be required to outline a plan for raising their pit card performance rates. Each plan will be discussed with the group and members will receive feedback from Floor Committee and Compliance Review Committee Members, and Compliance and Floor Department Staff. Members attending classes are strongly encouraged to bring their clerks with them!
- Upon completion of the class, members will be allowed to "do over" up to two subse-quent months in which their timely submission rates fall between 70% and 79%. No fine or warning letter will be issued for a "do over" month, but the month will not count as a passing month. A member who falls below 70% will receive a fine or warning letter.
- The benefit to the member will be that the month that would have counted as a failing month will not count at all, as long as the member achieved at least a 70% rate. Members still need four problem-free months to return to a warning letter stage. A member who has been problem-free for 3 months would benefit by "doing over" a fourth (and possibly a fifth) failing month, thus having the opportunity to return to the warning letter stage despite intervening failing months. A member who falls below 70% before achieving four problem-free months will receive a fine or a warning letter, as appropriate. The member can still use a second "do over" month as long as he meets all the above criteria.
- Staff will follow up with members attending the classes. Members will receive a breakdown of their most recent audit trail fine. They will also be invited to discuss their percentages with staff on an individual basis. Further, staff will supply daily or weekly statistics to any member by e-mail or telephone upon request.
- Members are eligible for only one class per year. A member must take a class to take advantage of the benefits listed herein. Classes will be offered on July 10 and August 15, 2001, and the program will apply to the next full month of audit trail statistics. The Compliance Review Committee and the Floor Committee will evaluate the results of this program before deciding whether to extend this program into 2002.