CME Group brought and settled over 20 disciplinary actions for payment of fines of between US $400 and $5,000 for violations of its requirement that all persons accessing Globex for a member firm use a unique identifier known as a Tag 50 User ID. In the cases, CME Group claimed that the clearing member firm failed to properly register Tag 50 User IDs and permitted orders to be entered on Globex without using the proper identifiers. Some firms received multiple sanctions. (Click here for a summary of CME Group’s Tag 50 requirements.)

Compliance Weeds: It is not the easiest task for clearing members to keep track of the specific identifications of each trader accessing exchange electronic systems. However, each designated contract market has a requirement like the CME’s requirement regarding identification of individual electronic system users, and firms, as a result, should maintain an accurate inventory containing such information—not only for their own personnel, but for traders of clients sponsored for access. Clients should often be reminded to comply with exchange requirements that each electronic order be accompanied by the identification of the specific trader placing the trade.