NOTICE OF DISCIPLINARY ACTION

MEMBER:

Alexander Perelberg

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 Alexander Perelberg (“Perelberg”) neither admitted nor denied the rule violations upon which the penalty is based, on March 28, 2017, a Panel of the CME Business Conduct Committee (“Panel”) found that on several dates between December 12, 2014 and January 31, 2015, Perelberg engaged in a pattern of activity in which he entered large manual orders in the March 2015 E-Mini NASDAQ 100 (“NASDAQ”) futures market without the intent to trade. Specifically, he entered these large orders to observe the market’s reaction and to encourage market participants to trade opposite his smaller iceberg orders that were resting on the opposite side of the book. After receiving fills on his iceberg orders, Perelberg would then cancel the resting large orders he had entered on the opposite side of the order book.

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

PENALTY:

In accordance with the settlement offer and after taking Perelberg’s financial condition into consideration when it levied the sanction, the Panel ordered Perelberg to pay $7,328.52 in disgorgement, to pay a fine of $5,000 and barred Perelberg from accessing any CME Group Inc. trading floor, and direct access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for three months, beginning on the effective date below and continuing through and including June 30, 2017.

EFFECTIVE DATE:

March 30, 2017