ICE US Futures has issued six disciplinary notices in October fining brokerage firms for failing to maintain and, when requested, to produce records of the audit trails for specific transactions. In one of the cases, ED&F Man Capital Markets was fined $2.5K for failing to maintain and produce electronic audit trail records for 4 transactions in 2016. The notice is here - https://www.theice.com/publicdocs/futures_us/disciplinary_notices/ED&F_Man_Capital_Markets_Ltd_2017-066%20.pdf
The fines all were either $2.5K or $5K - very small fines for very large companies. However, the CFTC Rules Review for ICE Futures in 2016 indicated that ICE failed to have documentation of certain necessary portions of their trading review. This pattern of going back and issuing fines to firms that also had documentation issues might indicate that ICE Futures is going to be focusing harder on firm documentation as they focus in on their own documentation.
This is one small reminder that the CFTC Rules Review for the exchanges can also indicate ares where the exchange may be placing greater focus due to the shortcomings the CFTC points out.
Good cause to either go back and review the CFTC reviews or chat with someone who does read them. Happy to have that conversation.