NON-MEMBER:
CHAO T. HO
EXCHANGE RULES: RULE 575.A. (DISRUPTIVE PRACTICES PROHIBITED)
All orders must be entered for the purpose of executing bona fide transactions. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.
A. 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.
FINDINGS:
Pursuant to an offer of settlement in which Chao T. Ho (“Ho”) neither admitted nor denied the rule violations upon which the penalty is based, on March 28, 2018, a Panel of the New York Mercantile Exchange (“NYMEX”) Business Conduct Committee (“BCC” or “Panel”) found that, on multiple dates from March 29, 2016 through July 13, 2016, Ho employed a trading strategy in the Platinum, Heating Oil and Crude Oil futures markets in which he entered and cancelled multiple layered orders without the intent to trade. Specifically, Ho entered these layered orders on one side of the market to encourage other market participants to trade his orders resting on the opposite side of the market. After receiving a fill on his resting smaller orders, Ho would then cancel the layered orders he had entered on the opposite side of the order book. As a result of this activity, Ho realized a profit of $1,752.09.
The Panel found that as a result of the foregoing, Ho violated Rule 575.A.
PENALTY:
In accordance with the settlement offer, the Panel ordered Ho to: 1) pay a $25,000 fine; 2) pay disgorgement in the amount of $1,752.09; and 3) serve a four (4) month suspension from any access to any CME Group Inc. trading floor and of direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc., including CME Globex. The suspension shall run from April 2, 2018 through July 27, 2018, inclusive.