by Howard Haykin

Lamberson Capital LLC  ... as an Exchange Trading Permit Holder ("ETP Holder") registered to act as a Market-Maker, Lamberson mismarked approximately 275 sell orders as “sell short” when the orders should have been marked as “sell long.”  [Regulation SHO, Rule 200]  [Case #18-0015; $7,500 fine]

Charles Schwab & Co., Inc.  ... as an ETP Holder approved to transact business with the public, Schwab, among other violative actions: (i) reported invalid or truncated account names to the Large Options Position Report (“LOPR”), (ii) submitted records to the LOPR with an invalid street address or city; (iii) submitted records to the LOPR with a Tax ID of zero and no postal code for foreign accounts; (iv)  failed to accurately report on standard and weekly expirations; and, (v) failed to report or failed to accurately report LOPR records. [Rule 4.13 – Reports Related to Position Limits]  [Case #18-0014; $300K fine]

Spot Trading L.L.C. ... as a Market-Maker and a proprietary trading firm, Spot Trading tendered 70,260 shares for the partial tender offer in CBS Corp. in excess of its net long position.  [Rule 14e-4 – Prohibited Transactions in Connection with Partial Tender Offers]  [Case #18-0013; $20K fine, $51K disgorgement]

RBC Capital Markets, LLC ... as an ETP Holder registered to conduct business as a Clearing Trading Permit Holder and Floor Broker, RBC: (i) entered a sell-side strategy order prior to the 8:15 a.m. cut-off time for participation in the Special Opening Quotation (“SOQ”) and subsequently changed its strategy order through its submission of buy-side orders after the 8:15 a.m. cut-off time; (ii) entered a sell-side strategy order prior to the 8:15 a.m. cut-off time for participation in the SOQ and subsequently changed its strategy order through its submission of buy-side orders after the 8:15 a.m. cut-off time.  [Rule 6.2B – Hybrid Opening System (“HOSS”)]  [Case #18-0012; $75K fine]

Andrie Trading LLC ... as an ETP Holder registered to conduct business on the Exchange as a Market-Maker, Andrie failed to maintain continuous electronic quotes when acting as an appointed Market-Maker in the Russell 2000 Index (“RUT”) option class and trading more than 20% of its contract volume through electronic orders. [Rules 1.1(ccc) – Continuous Electronic Quotes and 8.7 – Obligations of Market-Makers]  [Case #18-0006; $10K fine]

Belvedere Trading LLC ... was an ETP Holder registered to conduct business on the Exchange as a Market-Maker, Belvedere, on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available. [Rule 6.45B – Priority & Allocation of Trades in Index Options and Options on ETFs on CBOE Hybrid System]  [Case #17-0028; $7.5K fine]

Synergy Capital Management, LLC ... as an ETP Holder registered to conduct business on the Exchange as a Market-Maker, Synergy, on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available.  [Rule 6.45B – Priority and Allocation of Trades ... on the CBOE Hybrid System]  [Case #17-0021; $2.5K fine]

Optiver US, LLC ... as an ETP Holder registered to conduct business on the Exchange as a Market-Maker, Optiver, on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available.  [Rule 6.45B – Priority and Allocation of Trades ... on the CBOE Hybrid System]  [Case #17-0020; $7.5K fine]

Akuna Securities LLC ... as an ETP Holder registered to conduct business on the Exchange as a Market-Maker, Akuna, on numerous occasions, failed to grant priority to the highest bid and/or lowest offer when such bid or offer was available. [Exchange Rule 6.45B – Priority and Allocation ... on the CBOE Hybrid System]  [Case #17-0019; $5K fine]

CTC L.L.C. ... as an ETP Holder registered to conduct business on the Exchange as a Market Maker, CTC, on numerous 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.  [Rules 6.45A, 6.45B – Priority and Allocation ... on the CBOE Hybrid System, 6.81 – Order Protection]  [Case #'s 14-0203 and 17-0038; $7.5K fine]