The Division found that the Exchange maintained adequate trade practice surveillance and disciplinary programs. The Exchange reorganized its self-regulatory operations during the review period and hired experienced senior staff. These steps improved the Exchange's overall capability to perform its self-regulatory functions. The review noted that NYCE's computerized surveillance capability enabled the Exchange to monitor adequately for potential trading violations. In addition, the Exchange's trade practice investigations were thorough and well documented. Further, the staff reorganization resulted in a successful effort to complete and close old investigations and handle new investigations in a timely manner. The Division also found that the Exchange generally imposed adequate disciplinary sanctions for violations of its rules, and maintained appropriate and timely disciplinary procedures.
The report sets forth three recommendations for further improvement, which the Exchange must respond to within 60 days. Copies of the report are available from the Commission's Office of Public Affairs, Three Lafayette Centre, 1155 - 21st Street N.W., Washington, DC 20581, (202) 418-5080, or by accessing the Commission's website at www.cftc.gov.