On March 15, 2023, a subcommittee of the Exchange's Business Conduct Committee (BCC) determined that ABN AMRO Clearing USA LLC, formerly known as ABN AMRO Clearing Chicago, LLC, may have violated legacy Exchange Rule 2.22 (currently Rule 2.12) by misreporting open interest in multiple instances in an energy futures contract between June 2020 and July 2022 and Exchange Rule 6.15(a) by misreporting large trader positions in multiple instances in various energy futures and options contracts between May 2020 and December 2022. The BCC additionally determined that ABN AMRO may have violated Exchange Rule 4.01(b) by failing to administer its own procedures on reporting positions and lacking processes for reporting open interest and large trader positions at certain times or for certain contracts.