NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 12-8724-BC

MEMBER:

BUNGE CHICAGO, INC.
 

CBOT RULE VIOLATIONS:

RULE 536. RECORDKEEPING REQUIREMENTS FOR PIT, GLOBEX, AND
NEGOTIATED TRADES (in part)

B. Globex Order Entry

2. Electronic Audit Trail Requirements for Electronic Order Routing/Front- End Systems

Clearing members guaranteeing a connection to Globex are responsible for maintaining or causing to be maintained the order routing/front-end audit trail for all electronic orders, including order entry, modification, cancellation and responses to such messages (referred to as the “electronic audit trail”), entered into the Globex platform through the CME iLink® gateway. This electronic audit trail must be maintained for a minimum of 5 years, and clearing members must have the ability to produce this data in a standard format upon request of Market Regulation.

This electronic audit trail must contain all order receipt, order entry, order modification, and response receipt times to the highest level of precision achievable by the operating system, but at least to the hundredth of a second… The data must also contain all Fix Tag information and fields which should include, but is not limited to the following:

A record of all fields relating to order entry, including transaction date, product, Exchange code, expiration month, quantity, order type, order qualifier, price, buy/sell indicator, stop/trigger price, order number, unique transaction number, account number, session ID, Tag 50 ID, host order number, trader order number, clearing member, type of action, action status code, customer type indicator, origin, and timestamps. For executed orders the audit trail must record the execution time of the trade along with all fill information…

FINDINGS:

Pursuant to an offer of settlement in which Bunge Chicago, Inc. neither admitted nor denied the rule violations upon which the penalty is based, on June 12, 2013, a Panel of the CBOT Business Conduct Committee found that Bunge Chicago, Inc. failed to maintain complete audit trail data containing all required fields for five years as required by CBOT Rules. Bunge Chicago, Inc. mistakenly assumed that its Independent Software Vendors were maintaining the required audit trail. The Panel concluded that Bunge violated CBOT Rule 536.

PENALTY:

In accordance with the settlement offer, the Panel ordered Bunge Chicago, Inc. to pay a fine of $15,000.

EFFECTIVE:

June 26, 2013