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      • CME 15-0179-BC
      • Effective Date
      • 20 March 2017
    • MEMBER:

      Mark Francis Donahue


      Rule 532. Disclosing Orders Prohibited (in part)

      …[N]o person shall disclose another person’s order to buy or sell except to a designated Exchange official or the CFTC, and no person shall solicit or induce another person to disclose order information. An order for pit execution is not considered public until it has been bid or offered by open outcry. No person shall take action or direct another to take action based on non-public order information, however acquired. The mere statement of opinions or indications of the price at which a market may open or resume trading does not constitute a violation of this rule.

      Rule 539. Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited (in part)

      A. General Prohibition

      No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction…


      Pursuant to an offer of settlement in which Mark Donahue (“Donahue”) neither admitted nor denied the rule violations upon which the penalty is based, on March 16, 2017, a Panel of the CME Business Conduct Committee (“Panel”) found that on March 13, 2015, Donahue received a customer order to buy 40,000 September 2015 9900 – 9912 put spreads in Eurodollar options on futures. After receiving the buy order, Donahue spoke to a market maker and disclosed the customer’s nonpublic buy order information, including the side of the market and the size of the order, to the market maker before disclosing the order to the pit. After Donahue disclosed the nonpublic order information, he executed the market maker’s order opposite the customer order in the pit and therefore noncompetitively prearranged the execution of the customer order. The Panel concluded that Donahue thereby violated CME Rules 532 and 539.A.


      In accordance with the settlement offer, the Panel ordered Donahue to pay a fine of $20,000 and serve a 15 day suspension of access to any CME Group Inc. trading floor and of direct access to all electronic trading and clearing platforms owned or controlled by CME Group, Inc., including CME Globex. The suspension shall run from April 3, 2017, through April 17, 2017, inclusive.


      March 20, 2017