NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 16-0609-BC

MEMBER:

Mark Palmer

CME RULE VIOLATIONS:

Rule 575.A. Disruptive Practices Prohibited

No person shall enter or cause to be entered an order with the intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.

Rule 575.B. Disruptive Practices Prohibited

No person shall enter or cause to be entered an actionable or non-actionable message or messages with the intent to mislead other market participants.

FINDINGS:

Pursuant to an offer of settlement in which Mark Palmer (“Palmer”) neither admitted nor denied the rule violations upon which the penalty is based, on November 27, 2018, a Panel of the CME Business Conduct Committee (“Panel”) found that on several dates between November 1, 2016, and December 31, 2016, Palmer entered orders in the Lean Hog futures contract markets without the intent to trade those orders. The Panel specifically found that Palmer’s trading strategy involved placing small orders at multiple price levels on one side of the market to encourage market participants to trade opposite his resting one-lot order on the other side of the market. After receiving a fill on the one-lot order, Palmer would then cancel his layered orders.

The Panel found that as a result of the foregoing, Palmer violated CME Rules 575.A. and 575.B.

PENALTY:

In accordance with the settlement offer, and after taking Palmer’s financial condition into consideration when it levied the sanction, the Panel ordered Palmer to pay a fine of $15,000 and to serve a four-month suspension from accessing any CME Group Inc. trading floor, and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. The suspension shall begin on the effective date below and continue through and include March 27, 2019.

EFFECTIVE DATE:

November 29, 2018