MARKET REGULATION ADVISORY NOTICE______________________________________________________________________
Exchange

CME, CBOT, NYMEX & COMEX

Subject

Documentation of Customer Orders and Submission of
Suspense Accounts on CME Globex

Rule References

Rule 536

Advisory Date

August 30, 2021

Advisory Number

CME Group RA2115-5

Effective Date

October 1, 2021

Effective on trade date Friday, October 1, 2021, and pending all relevant CFTC regulatory review periods,
this Market Regulation Advisory Notice will supersede CME Group Market Regulation Advisory Notice
RA2011-5 from September 2, 2020. It is being issued based on amendments to CBOT Rule 536.C.
(“Bunched Orders and Orders Eligible for Post Execution Allocation””) in connection with the September
30, 2021, closure of the trading floor for all products other than options on CME Eurodollar futures andoptions on CME SOFR futures.
No substantive information in this Advisory Notice has been amended.
Since October 1, 2018, this Advisory Notice has set forth the circumstances under which a suspense
account may be submitted on orders entered into CME Globex (“Globex”) and the requirements attendant
to proper documentation of such orders. For purposes of this Advisory Notice, a suspense accountmeans a temporary holding account that is submitted at the time of order entry into Globex but prior to theallocation of the executions to the specific accounts on a carrying Clearing Member Firm’s books.
No other material changes have been made to the Advisory Notice.
The text of Rule 536.B. (“Globex Order Entry”) and Rule 536.C. (“Bunched Orders and Orders Eligible for
Post Execution Allocation”) which are, in part, applicable to the use of suspense accounts, begins on
page 5. A Frequently Asked Questions (“FAQ”) section begins on page 8.
This MRAN does not apply to 1) the entry of block trades and Exchange for Related Position
Transactions (“EFRPs”) submitted via CME ClearPort/CME Direct and 2) trades executed via open outcry
in a trading pit.
Entry of Suspense Accounts into Globex
The Exchanges recognize the following five circumstances where a suspense account may be used at
the time of order entry into Globex, subject to the requirements and limitations set forth in this Advisory
Notice:-Orders entered by or on behalf of an Eligible Account Manager (“EAM”) that has written
investment discretion over the accounts of customer(s) (“EAM-Specific Suspense Accounts”);-

Bunched DRT orders for multiple customers where the resulting trades are subject to a written
pre-determined allocation scheme (“Bunched DRT Suspense Accounts”);-

Orders subject to a written pre-determined allocation scheme (“Pre-Determined Allocation
Scheme Suspense Accounts”);

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Bunched Request for Cross (“RFC”) orders (“Bunched RFC Order Suspense Accounts”); and-De minimis usage for orders entered by Execution Operations (“Execution Operation Suspense
Accounts”)

Unless otherwise provided below, Market Regulation will conduct examinations of Exchange Clearing
Member Firms and their guaranteed introducing brokers (“IBs”) related to their usage of suspense
accounts. The use of suspense accounts must comport with the requirements detailed in this Advisory
Notice and such use is subject to a heightened level of regulatory scrutiny. No other use of suspense
accounts for order entry into Globex is permitted.
EAM-Specific Suspense Accounts
Persons or entities that qualify as an EAM, as defined in CFTC Regulation 1.35(b)(5)(i), with written
investment discretion regarding participating customer accounts may enter orders for those customers,
including bunched orders on behalf of multiple customers, into Globex using a suspense account. An
EAM that has granted written investment discretion to another EAM is considered a customer of that
other EAM. In all cases, the suspense account must be unique to the EAM responsible for the order
entry. For purposes of this Advisory Notice, this is referred to as an “EAM-Specific Suspense Account.”
Any post-execution allocation of the resulting executions must be done in compliance with CFTC
Regulation 1.35(b)(5) and the National Futures Association Interpretive Notice related to National Futures
Association (“NFA”) Compliance Rule 2-10, including recordkeeping requirements.
Bunched DRT Suspense Accounts
A DRT order (Disregard Tape or Not-Held Order) means an order placed by an account owner orcontroller that gives a person complete discretion over price and time in the execution of the order,
including discretion to execute all, some, or none of the order.
A person in possession of DRT orders for multiple customers may bunch those orders and enter theminto Globex using a suspense account provided the following conditions are met:

1. The account owner or controller must have consented to having its orders bunched with other
DRT orders and must further have consented to having its trade executions average priced withthe trade executions of the other orders included in the bunched order.

2. The person bunching the DRT orders must create, prior to the entry of the bunched DRT order
into Globex, a written or electronic record of each underlying customer order in accordance with
Rule 536.B.1. The underlying customer order must reflect that the order was a DRT order andinclude an electronic timestamp reflecting the date and time the order was received and thecustomer-specific account designation.

3. The person bunching the DRT orders or entering the bunched DRT order into Globex must use asuspense account that specifically identifies or is unique to the person responsible for thebunching of the DRT orders. That suspense account must be used solely for bunching DRT
orders.

4. Prior to the entry of a bunched order into Globex, the executing Clearing Member Firm must be
provided the methodology to be used to allocate the trade executions to the customer accounts
participating in the bunched DRT order. The methodology must address how trade executions
should be allocated in instances where only part of the bunched DRT order is executed.

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5. All trade executions for the bunched DRT orders must be averaged priced in accordance with
Rule 553 (“Average Price System”) prior to the allocation of the executions to the underlying
customer accounts.

6. A person bunching DRT orders must make the executing Clearing Member Firm and any carrying
Clearing Member Firms aware that it is engaged in bunching DRT orders.
Pre-Determined Allocation Scheme Suspense Accounts
Orders subject to a pre-determined allocation scheme may be entered into Globex using a suspense
account provided the following conditions are met:
1. Each allocation scheme must use a unique suspense account. The Pre-Determined Allocation
Scheme Suspense Account may not be used for orders not subject to the allocation scheme.
2. Prior to the entry of orders into Globex, the executing Clearing Member Firm must be provided
the pre-determined allocation scheme to be used for the resulting trade executions.
3. Each customer or participant must consent to having their orders subjected to the pre-determinedallocation scheme.
4. The executing Clearing Member Firm must maintain records of all Pre-Determined Allocation
Scheme Suspense Accounts and their pre-determined allocation schemes for a minimum of five
years.
Bunched RFC Order Suspense Accounts
In those circumstances where order entry into Globex occurs via the submission of a Request for Cross(“RFC”) (an order which contains both the buy and the sell orders) pursuant to the requirements of
Exchange Rule 539.C. (“Pre-Execution Communications Regarding Globex Trades”), a broker may bunch
multiple market maker orders for the purpose of satisfying the terms of a single customer order and enter
the bunched market maker order using a Bunched RFC Order Suspense Account.
The Bunched RFC Order Suspense Account may not be used to represent the customer side of the RFC
order. Where a Bunched RFC Order Suspense Account is used on the market maker side of the order,
brokers must ensure that the market maker orders are documented in accordance with Rule 536.B.1 withspecific market maker account identifiers on the order tickets. Brokers must obtain a Bunched RFC
Orders Suspense Account, unique to the individual broker placing the bunched RFC orders from their
Clearing Member Firm and may use that suspense account solely for purposes of entering the bunchedmarket maker orders on one side of an RFC. Allocations to end-clients are required to be completed in
the CME clearing system before the end of the clearing session for that trade date.
Execution Operation Suspense Accounts
For operations that provide order execution services for customers (“Execution Operations”), orders must
generally be entered into Globex using a customer-specific account number or short code on each order
entry at the time of entry into Globex. Where the order is entered immediately upon receipt and the order
entry includes the customer-specific account number or short code, the Execution Operation has met its
order documentation requirements as defined below and as set forth in Rule 536.B.
Orders received by an Execution Operation from an EAM with discretion over the customer account(s)represented by the order must be entered into Globex using a suspense account specifically identifying or
mapping to the EAM responsible for the order or using the customer-specific account number or shortcode.

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Recognizing that on occasion a customer-specific or EAM-specific account may not be available at thetime an order is entered into Globex, de minimis usage of an Execution Operation Suspense Account will
be permitted, provided the following requirements are met.
1. If a general suspense account is used rather than a customer-specific or EAM-specific account,the Execution Operation must create, prior to order entry, a written or electronic record of theorder in accordance with Rule 536.B.1. The order must reflect the time of receipt of the order anda customer-specific or EAM-specific account designation.
2. The general suspense account must be unique to the desk or group of the Execution Operation
submitting the order into Globex.
Market Regulation will conduct examinations of the usage of Execution Operation Suspense Accounts by
Exchange Clearing Member Firms, their guaranteed IBs, as well as floor-based member-owned Globex
Execution Operations. The examination will include a recordkeeping review to verify written or electronic
records of the order are created and maintained in accordance with Rule 536.B.1.
The examination will also include a review to determine whether the Execution Operation Suspense
Accounts were used on more than a de minimis basis. In considering whether usage was more than deminimis, Market Regulation will consider a variety of factors, including whether the orders and or trades
were for new accounts where account information may not have been available to the Globex terminal
operator.
Limitations Applicable to All Suspense Accounts
Except for a Commodity Trading Advisor (“CTA”) who has permission of its customer(s), no other personor entity is allowed to enter customer orders into a suspense account that is also used for personal or
proprietary orders of the party entering the order (i.e. where the resulting trades will be given-up or
allocated to an account in which the party entering the order has an ownership or financial interest).
For instances where the resulting trades will be given-up from the executing firm to a carrying Clearing
Member Firm, the executing firm must be a party to a written agreement with the carrying Clearing
Member Firm pursuant to CFTC Regulation 1.73, where applicable.
Exchange Clearing Member Firm Requirements Concerning Suspense Account Records
Exchange Clearing Member Firms are reminded of the requirement to provide, upon request from Market
Regulation, records of all suspense accounts used at the firm.
The records must include the account number, the name of the party it represents, the name of the entity
using it for submitting orders, the type of suspense account, and where applicable, any pre-determinedallocation scheme associated with the suspense account. Additionally, if a short code is used at order
entry for a customer, the Exchange Clearing Member Firm must maintain a record of the accountnumber(s) to which the short code maps. Exchange Clearing Member Firms should maintain procedures
related to the assignment, collection and preservation of records and documentation, and monitoring theuse of suspense accounts. Exchange Clearing Member Firms must be able to produce these records in astandard format upon request of Market Regulation.

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CME
536.B. Globex Order Entry
1. General Requirement
Each Globex Terminal Operator entering orders into Globex shall accurately input for each Application Message
all fields required to be populated by the CME iLink® Message Specifications set forth in the CME Group Client
Systems Wiki in effect at the time, including, but not limited to the: operator ID; price; quantity; product; expiration
month; CTI code; manual order indicator; and account number (except as provided in Section C), and, for
options, put or call and strike price. The Globex Terminal Operator’s operator ID must be present on eachApplication Message, including order messages, submitted to Globex. For a Globex Terminal Operator withaccess pursuant to Rule 574, t h e clearing member that guarantees such access to Globex will be responsible
for the Globex Terminal Operator’s compliance with this rule with respect to the following fields: operator ID, CTI
code, manual order indicator and account number. Notwithstanding, and in accordance with Rule 574, a clearing
member must take appropriate action if it has actual or constructive knowledge that a Globex Terminal Operator
has failed to accurately input for each Application Message fields required to be populated by this rule.
With respect to orders received by a Globex Terminal Operator which are capable of being immediately enteredinto Globex, no record other than that set forth above need be made. However, if a Globex Terminal Operator
receives an order which cannot be immediately entered into Globex, the Globex Terminal Operator must preparea written order and include the account designation, date, time of receipt and other information required pursuant
to section A.1. above. The order must be entered into Globex when it becomes executable.
2.
Electronic Audit Trail Requirements for Electronic Order Routing/Front-End Systems
Entities certified by the Exchange to connect an order routing/front-end system to the Globex platform through the
CME iLink® gateway are responsible for causing an audit trail of each message entered into Globex to be created.
Clearing members guaranteeing a connection to Globex are responsible for maintaining or causing to be
maintained the electronic audit trail for such systems. This electronic audit trail must be maintained for a minimumof 5 years, and clearing members must have the ability to produce this data in a standard format upon request ofMarket Regulation.
Each such electronic audit trail must be complete and accurate and account for every electronic communicationsuch system sends to or receives from Globex.
This electronic audit trail must contain all order entry, order modification, and Globex response receipt times to thehighest level of precision achievable by the operating system, but at least to the millisecond. The times captured
must not be able to be modified by the person entering the order. The data must also contain all required
information and fields which include, but 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, operator ID, manual order indicator, self-match prevention ID whereapplicable, 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.
In the case where the guaranteeing Clearing Firm has a direct connect client that is another Clearing Firm or an
Equity Member Firm, the Clearing Firm may notify the client Clearing Firm or Equity Member Firm that it is their
obligation to maintain the electronic audit trail. Upon execution of this written notice, it shall be the duty of the client
Clearing Firm or Equity Member Firm to maintain an electronic audit trail pursuant to this rule. Nothing herein
relieves any of the above-referenced firms from compliance with the applicable recordkeeping provisions of CFTC
Regulations, including Regulation 1.31 or 1.35.
536.C. Bunched Orders and Orders Eligible for Post Execution Allocation
Bunched orders must be allocated and recorded in accordance with CFTC Regulation 1.35(b) and the NFA’s
Interpretive Notice related to Compliance Rule 2-10. A bunched order for pit execution does not require the specificaccount number to be recorded at the time of order placement or upon the report of execution provided that 1) theorder is being placed by an eligible account manager for multiple accounts eligible for post execution allocation or2) a written, pre-determined allocation scheme has been provided to the futures commission merchant accepting
or clearing the order prior to the time the order has been placed. Additionally, at the time of receipt on the trading
floor, bunched orders that do not contain specific account numbers must contain a series, group, or suspense
account indicator which relates directly to the group of accounts for which the order has been placed. A bunchedorder may be initially cleared into a suspense account provided that the final account-specific allocations are
submitted to the clearing system no later than the end of each trading day.

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Bunched orders for non-discretionary accounts may be entered for pit execution; however, only the following ordertypes may be bunched: Market on Open, Market on Close, same priced Limit Orders and same priced Stop Orders.
Such non-discretionary orders may only be bunched in the following instances:a. Each order underlying the bunched order must be reduced to writing and include the information required
pursuant to Section A.1. above;
b. Allocation of the executions for the bunched orders must be fair and equitable in accordance with the
NFA’s Interpretive Notice related to Compliance Rule 2-10; andc. In circumstances where the order is bunched in a member firm’s sales office, the party accepting theorder must, contemporaneously with the order placement, transmit the individual account numbers andquantities associated with the bunched order to the clearing member firm. Such transmission shall bemaintained by the clearing member firm along with the bunched order.
With respect to bunched Globex orders, such orders may be entered using a series designation or suspense
account number provided that 1) the order is being placed by an eligible account manager for multiple accounts
eligible for post execution allocation or 2) a written, pre-determined allocation scheme that defines the series has
been provided to the futures commission merchant accepting or clearing the order prior to the time that such orderis entered. In the latter case, if such information has not been provided to the futures commission merchant prior
to the time of order entry, each specific account number must be entered into Globex. Additionally, for all suchbunched orders executed on Globex, the final account specific allocations must be submitted to the clearing systemno later than the end of each trading day.

CBOT and NYMEX/COMEX
536.B. Globex Order Entry
1. General Requirement
Each Globex Terminal Operator entering orders into Globex shall accurately input for each Application Message
all fields required to be populated by the CME iLink® Message Specifications set forth in the CME Group Client
Systems Wiki in effect at the time, including, but not limited to the: operator ID; price; quantity; product; expiration
month; CTI code; manual order indicator; and account number (except as provided in Section C), and, for options,put or call and strike price. The Globex Terminal Operator’s operator ID must be present on each Application
Message, including order messages, submitted to Globex. For a Globex Terminal Operator with access pursuant
to Rule 574, the clearing member that guarantees such access to Globex will be responsible for the Globex
Terminal Operator’s compliance with this rule with respect to the following fields: operator ID, CTI code, manual
order indicator and account number. Notwithstanding, and in accordance with Rule 574, a clearing member musttake appropriate action if it has actual or constructive knowledge that a Globex Terminal Operator has failed toaccurately input for each Application Message fields required to be populated by this rule.
With respect to orders received by a Globex Terminal Operator which are capable of being immediately enteredinto Globex, no record other than that set forth above need be made. However, if a Globex Terminal Operator
receives an order which cannot be immediately entered into Globex, the Globex Terminal Operator must preparea written order and include the account designation, date, time of receipt and other information required pursuant
to section A.1. above. The order must be entered into Globex when it becomes executable.
2. Electronic Audit Trail Requirements for Electronic Order Routing/Front-End Systems
Entities certified by the Exchange to connect an order routing/front-end system to the Globex platform through the
CME iLink® gateway are responsible for causing an audit trail of each message entered into Globex to be created.
Clearing members guaranteeing a connection to Globex are responsible for maintaining or causing to be
maintained the electronic audit trail for such systems. This electronic audit trail must be maintained for a minimumof 5 years, and clearing members must have the ability to produce this data in a standard format upon request ofMarket Regulation.
Each such electronic audit trail must be complete and accurate and account for every electronic communicationsuch system sends to or receives from Globex.
This electronic audit trail must contain all order entry, order modification, and Globex response receipt times to thehighest level of precision achievable by the operating system, but at least to the millisecond. The times captured
must not be able to be modified by the person entering the order. The data must also contain all required
information and fields which 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, operator ID, manual order indicator, self-match prevention ID whereapplicable, host order number, trader order number, clearing member, type of action, action status code, customer

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type indicator, origin, and timestamps. For executed orders the audit trail must record the execution time of the
trade along with all fill information.
In the case where the guaranteeing Clearing Firm has a direct connect client that is another Clearing Firm or an
Equity Member Firm, the Clearing Firm may notify the client Clearing Firm or Equity Member Firm that it is their
obligation to maintain the electronic audit trail. Upon execution of this written notice, it shall be the duty of the client
Clearing Firm or Equity Member Firm to maintain an electronic audit trail pursuant to this rule. Nothing herein
relieves any of the above-referenced firms from compliance with the applicable recordkeeping provisions of CFTC
Regulations, including Regulation 1.31 or 1.35.
536.C. Bunched Orders and Orders Eligible for Post Execution Allocation
Bunched orders must be allocated and recorded in accordance with CFTC Regulation 1.35(b) and the NFA’s
Interpretive Notice related to Compliance Rule 2-10.
With respect to bunched Globex orders, such orders may be entered using a series designation or suspense
account number provided that 1) the order is being placed by an eligible account manager for multiple accounts
eligible for post execution allocation or 2) a written, pre-determined allocation scheme that defines the series has
been provided to the futures commission merchant accepting or clearing the order prior to the time that such orderis entered. In the latter case, if such information has not been provided to the futures commission merchant prior
to the time of order entry, each specific account number must be entered into Globex. Additionally, for all suchbunched orders executed on Globex, the final account specific allocations must be submitted to the clearing systemno later than the end of each trading day.

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Frequently Asked Questions (FAQ)
Documentation of Customer Orders andSubmission of Suspense Accounts on CME Globex
1.

What is a suspense account?
A suspense account is a generic account used at the time of order entry into Globex totemporarily hold a trade execution that is subsequently allocated to a customer specific account.
Only the following five types of suspense accounts are permitted by Market Regulation:
•
•
•
•
•

EAM-Specific Suspense Accounts
Bunched DRT Suspense Accounts
Pre-Determined Allocation Scheme Suspense Accounts
Bunched RFC Order Suspense Accounts
Execution Operation Suspense Accounts

In all other circumstances, a customer-specific account number must be used at the time of order
entry into Globex.
2.

What is a short code?
A short code is a customer-specific identifier used at order entry in lieu of the actual customer
account number. A customer-specific short code is not considered a suspense account. If aunique customer-specific short code is used at order entry and the order is entered into Globex
immediately upon receipt from the customer, the executing entity has met its order documentation
requirements. If the order is not immediately entered upon receipt, a timestamped order ticket
must be generated and maintained pursuant to Rule 536.B.1.

3.

Who qualifies as an Eligible Account Manager (“EAM”) for purposes of using an EAMSpecific Suspense Account?
Those individuals and entities qualifying as an Eligible Account Manager (“EAM”) pursuant to
CFTC Regulation 1.35.

4.

What type of information must be maintained with respect to the use of suspense
accounts?
Exchange Clearing Member Firms should be able to produce records for any order entry into
Globex using a suspense account for up to five years, with records for the most recent fourmonths of activity readily available. Firms must have the ability to produce the following records ina standard format upon request from Market Regulation:
•
•
•

•
•

Type of suspense accountSuspense account number
Name/description of executing party authorized to use the suspense account:o Associated National Futures Association (“NFA”) ID and/or US Securities andExchange Commission (“SEC”) #, if any
o EAM Type, if any
Name/description of party represented by the suspense accounto Associated NFA ID and/or SEC #, if any; ando EAM Type, if any
Where applicable, any pre-determined allocation scheme associated with the suspense
account.

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Market Regulation will conduct examinations of Exchange Clearing Member Firms and theirguaranteed introducing brokers for their compliance with this rule.
5.

What are the recordkeeping requirements for Execution Operation Suspense Accountusage?
For orders entered into Globex using an Execution Operation Suspense Account, a written or
electronic record must be created or captured prior to order entry. Documentation of such orders
may include any of the following records: written order tickets, instant messages, recorded phone
calls, or emails.
It is important to note that such records must contain the time the order was received as well asan account identifier which represents the customer that originated the order. Upon examination,
it should be clear to Market Regulation when the order was received and who originated theorder.

6.

How should a DRT order be documented by a party using a Bunched DRT Suspense
Account?
Each underlying order of a bunched DRT order must have a designation of “DRT.” Parties may
write “DRT” on an order ticket, communicate the order is “DRT” on electronic communications
including an email or instant message, or verbally confirm “DRT” on a recorded phone line.

7.

What is a Letter of Direction (“LOD”), and may a firm use a suspense account for the entryof multiple orders executed pursuant to LODs?
A LOD is typically an authorization from a customer granting limited power of attorney anddiscretion to a broker or futures commission merchant (“FCM”) to enter orders in accordance withsignals and/or recommendations generated by a trading system developed by the customer or
licensed or purchased from a third party by the customer. To the extent the person or entity
entering the orders generated by such system(s) is an EAM, an EAM-Specific Suspense Accountmay be used at order entry, including instances where the EAM bunches orders on behalf ofmultiple customers. If the person or entity entering the orders generated by such system(s) is not
an EAM and intends to bunch orders from multiple customers, all requirements for Bunched DRT
Orders must be satisfied.

8.

What is a Pre-Determined Allocation Scheme?
A Pre-Determined Allocation Scheme is a detailed description of how order executions should beallocated to underlying customer accounts. The scheme should contain the identity or accountnumber of each underlying customer, the quantity to be allocated, and the method of allocation in
the event of a partial fill. Executing Clearing Member Firms must be provided with such details
prior to entering orders into a Pre-Determined Allocation Scheme Suspense Account, and theallocations should not deviate from the scheme without the executing Clearing Member Firmbeing notified of the changes to the scheme prior to the time the orders are entered into Globex.

9.

May an execution operation use an Execution Operation Suspense Account when enteringorders into Globex where the customer is an EAM?
Generally, the firm must use a customer-specific account number or an account number that
represents the EAM utilizing the services of the execution operation. Recognizing that on
occasion a customer-specific or EAM-specific account number may not be available at the time
an order is entered into Globex, an Execution Operation Suspense Account may be used on a deminimis basis for entry of such orders into Globex.

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At what entity level is the usage of Execution Operation Suspense Accounts measured inorder to ensure it remains de minimis?
The usage of Execution Operation Suspense Accounts will be measured at the executing level.
The executing level may be the NFA registered entity utilizing the suspense account or individual
members utilizing the suspense account while acting as an execution operation. Affiliates of
Exchange Clearing Member Firms registered under separate NFA IDs will be measured
separately.

11.

May orders for the personal trading accounts of an employee of an execution operation beentered using an Execution Operation Suspense Account?
No. The employees or agents of an execution operation may not enter orders for their own
trading accounts or the trading accounts of any other execution operation employee or agent into
Globex using an Execution Operation Suspense Account.

12.

What types of violations regarding the use of suspense accounts will Market Regulation
seek to identify?
Market Regulation’s review of suspense accounts usage will be focused on, but not limited to,
identifying the following types of violations:•

All Suspense Accounts
o Failure to maintain or adhere to firm procedureso Failure to maintain records of suspense accounts used by the firmo Failure to identify a suspense accounto Violation of personal trading restrictions•

Bunched DRT Suspense Accounts
o Improper Use:▪ Bunching customer orders without customer consent▪ Executing non-bunched orderso Missing required documentationo Inaccurate Documentation:▪ Missing time of receipt indication▪ Time of receipt indication after order entry▪ Missing or invalid customer-specific account designation▪ Missing “DRT” designationo Failure to provide the executing Clearing Member Firm, prior to the entry of abunched order into Globex, the methodology to be used to allocate the trade
executions to the customers participating in the bunched order.
o Failure to average price the order(s) prior to the allocation to underlying customer
accounts.

•

Pre-Determined Allocation Scheme Suspense Accounts
o Improper Use:
▪ Used for multiple schemes or orders that are not a part of the scheme▪ Subjecting customer orders to a pre-determined allocation scheme without
consent.
o Failure to provide the executing firm, prior to order entry, with the pre-determinedallocation scheme.
o Failure to maintain records of schemes for a minimum of 5 years.

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Bunched RFC Order Suspense Accounts
o Improper Use:
▪ Used to represent the customer side of an RFC order.
▪ Used for non-RFC orderso Missing required documentationo Inaccurate Documentation:▪ Missing time of receipt indication▪ Time of receipt indication after order entry▪ Missing or invalid customer-specific account designation▪ Missing or invalid market maker identifiers•

Execution Operation Suspense Accounts
o Improper Use:
▪ Exceeding de minimis usage▪ Violating personal trading restrictionso Missing required supporting documentationo Inaccurate documentation▪ Missing time of receipt indication▪ Time of receipt indication after order entry▪ Missing or invalid customer-specific account designation

Questions regarding this Advisory Notice may be directed to the following individuals in Market
Regulation:
Terrence Quinn, Manager, Data Investigations, 312.435.3753
Laetizia Moreau, Senior Director, Data Investigations, 312.435.3619
Andrew Carr, Investigations Specialist, Data Investigations, 312.435.3610
Erin Middleton, Director, Rules & Regulatory Outreach, 312.341.3286
Paige Gawrys, Senior Specialist, Rules & Regulatory Outreach, 312.872.5078

For media inquiries concerning this Advisory Notice, please contact CME Group Corporate Communications at 312.930.3434 or
news@cmegroup.com.