Rule 14E-4 – RE: PARTIAL SHORT TENDER OFFERS

• Citigroup Derivatives Markets ... as an Exchange Trading Permit Holder (“TPH”) registered to conduct business as a Market-Maker, CDMI tendered 112,793 shares for the partial tender offer in HAL in excess of its net long position. CDMI agreed to pay $73K in fines and disgorgement to settle CBOE charges. [Case $18-11 - $73K in fines and disgorgement.]

• Bengal Capital Trading ... as a TPH registered to conduct business as a Proprietary Trading firm, Bengal tendered 23,300 shares for the partial tender offer in CBS in excess of its net long position. [Case #18-10 - $44K in fines and disgorgement.]

RULE 6.75 – DISCRETIONARY TRANSACTIONS

• Wolverine Execution Services ... as a TPH registered to conduct business as a Floor Broker, WEX, on multiple occasions, simultaneously held a “not held” market order to buy and a “not held” market order to sell the same series of options for the same account. [Case #17-64 - $75K fine]

RULE 3.6A – PERSONS ASSOCIATED WITH TPH ORGANIZATIONS

• Israel A. Englander & Co ... as  a TPH registered to conduct business on the Exchange as a Floor Broker, Englander failed to qualify and register an Associated Person as a Proprietary Trader (PT) over a 4-year period and then, over the subsequent 15 months, failed to register and qualify the Associated Person as a Securities Trader. [Case #17-47 - $5K fine]

RULE 6.45 – ORDER AND QUOTE PRIORITY AND ALLOCATION

• Ronin Capital ... as a TPH registered to conduct business on the Exchange as a Market Maker, Ronin, on

  numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer

  was available. [Case #’s 15-22 and 17-17 - $2.5K fine]

• Susquehanna Securities ... as a TPH registered to conduct business on the Exchange as a Market Maker, Susquehanna, on multiple occasions: (i) failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available; and,(ii) traded through the National Best Bid or Offer (NBBO). [Case #’s 15-22 and 17-17 - $7.5K fine]

• Global Execution Brokers ... as a TPH registered to conduct business on the Exchange as a Floor Broker, GEB, on multiple occasions: (i) failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available; and, (ii) failed to use due diligence to execute orders at the best prices available. [Case #’s 15-16 and 17-40 - $5K fine]

[For further details on any of these cases, click on the Broker-Dealer's name .]