Bertram Consultants Limited
CME RULE VIOLATION:
Rule 575 Disruptive Practices Prohibited
D. No person shall enter or cause to be entered an actionable or non-actionable message with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.
Pursuant to an offer of settlement in which Bertram Consultants Limited (“Bertram”) neither admitted nor denied the rule violation upon which the penalty is based, on August 30, 2017, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that from March 2015 to June 2015 Bertram accumulated a short position of 378 contracts in the June 2015 NASDAQ 100 (“June 2015 NASDAQ”) futures market. Bertram received several reminders and notifications regarding CME’s planned delisting and cessation of trading of the NASDAQ 100 futures contract scheduled for June 18, 2015. Despite the outstanding short position and lack of liquidity in the market, Bertram waited until several minutes prior to the close of regular trading on the afternoon of June 18, 2015, to place with a floor broker a single Market on Close order for all 378 contracts. The execution of the order resulted in price and volume aberrations in the June 2015 NASDAQ market in both the pit and on Globex. The Panel concluded that Bertram violated CME Rule 575.D.
In accordance with the settlement offer, the Panel ordered Bertram to pay a fine of $50,000.
September 1, 2017