06/19/2003
A key feature of the amendments was the added functionality of a type 2C trade type applicable to non-clearing member firms which applies a member rate to such transactions. At the time of the Notice, clearing members and floor members were advised to coordinate efforts to change any pre-existing short codes for member firms from 4C to 2C. Additionally, summaries of short code files were supplied to clearing member operations managers to assist in identifying the short codes needing modification. In spite of the efforts made, many requests for member credits were made and processed for the months of April and May.
On Tuesday, June 17, 2003, the Clearinghouse placed copies of the short code summary reports in all clearing member lock boxes. Clearing members are required to identify short codes related to member firms while they accept business or which are recorded as 4C and should be amended to 2C. Requests to the appropriate floor personnel should be documented and retained for presentation to the Compliance Department should it be requested in connection with a review of credits requested by the clearing member.
Floor member representatives should promptly facilitate requested changes to the short code files by clearing members. The failure of clearing members and/or floor members or their representatives to properly process changes to allow for proper CTI coding as prescribed by NYMEX Rule 6.19 may ultimately result in disciplinary action.