EXCHANGE RULES: NYMEX RULE 432. GENERAL OFFENSES
It shall be an offense:
L.1. to fail to appear before the Board, Exchange staff or any investigative or hearing committee at a duly convened hearing, scheduled staff interview or in connection with any investigation.
NYMEX RULE 576 (IDENTIFICATION OF GLOBEX TERMINAL OPERATORS)
Each Globex terminal operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If user IDs are required to be registered with the Exchange, it is the duty of the clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique user ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.
Following an evidentiary hearing on the merits on April 5, 2016, a Panel of the NYMEX Business Conduct Committee (“Panel”) issued a written decision finding that Ivonne Ruggles (“Ivonne”), a non-member, was subject to the jurisdiction of the Exchange pursuant to NYMEX Rules 402 and 418 for the time period of August 20, 2012 through December 10, 2012. The Panel also found that pursuant to Legacy Rule 402.D., it had the authority to suspend or ban Ivonne from trading on the Exchange for rule violations occurring before August 20, 2012.
The Panel found that during the time period from April 18, 2012 through December 10, 2012, Ivonne permitted her husband to use her Tag 50 I.D. to enter trades associated with her accounts. Specifically, the Panel found that the IP addresses that were associated with the majority of trading activity in both accounts were mapped and registered to her husband’s employer’s office. Furthermore, Market Regulation was advised that Ivonne did not execute any of the trades in either of her personal accounts, which the Panel concluded meant that Ivonne authorized her husband to improperly use her Tag 50 I.D. to execute the trades.
Furthermore, the Panel found that Market Regulation requested that Ivonne appear for an interview in connection with the trading by her husband. Interviewing witnesses and potential subjects of an investigation is a standard investigative procedure by Exchange staff. Despite receiving a request to appear for an interview, Ivonne, through her counsel, declined to be interviewed.
Accordingly, the Panel found that Ivonne violated NYMEX Rules 432.L.1. and 576.
Based on the record and the Panel’s findings and conclusions, the Panel ordered that Ivonne be permanently barred from (i) applying for membership at any CME Group Inc. exchange; (ii) accessing any trading floor owned or operated by any CME Group Inc. exchange; and (iii) directly or indirectly accessing any trading or clearing platform owned or operated by the CME Group, Inc., including CME Globex.
Please see companion case Jon Ruggles, NYMEX 12-9153-BC-1.
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