One warning notice per 12 month period before you get fined - CME warns you again

The CME published an Market Regulation Advisory Notice today regarding summary fines for reporting infractions (what I like to call exchange traffic tickets). These are the fines for EFRP or Block or Large Trader reporting issues. There is a list of items - many of which are more applicable to broker/dealers than traders or firms hedging through the exchange. However, the CME points out that though the CME can - at its discretion - issue a warning notice, CFTC regulations allow them no more than 1 warning notice per 12 month period for a type of violation. After that, the CME is required to impose a fine. The fine is no less than $1K and no more than $5K for an individual or $10K for a firm per offense.
These are areas that the CFTC has repeatedly raised in its rules review with the exchanges noting that the CFTC feels too many reporting errors have been noted but not subject to a fine.
This type of summary market advisory notice is intended to direct companies to pay more attention since the CME feels it has to be stricter regarding the issuance of fines. It is the right time to review, and possibly test, your reporting controls to make sure you don't end up with a bunch of traffic tickets. Feel free to reach out to us if you have questions.
The full notice is here - https://www.cmegroup.com/content/dam/cmegroup/notices/ser/2018/11/RA-1812-5.pdf