NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 16-0548-BC

MEMBER:

Jared Kuehner

CBOT RULE VIOLATIONS:

Rule 575 (“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 Jared Kuehner (“Kuehner”) neither admitted nor denied the rule violation upon which the penalty is based, on June 13, 2018, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on multiple occasions between January 2016 and July 2016, Kuehner entered orders for various CBOT Grains futures contracts on the Globex electronic trading platform during the pre-opening period that were not entered in good faith for the purpose of executing bona fide transactions. The entry and cancellation of these orders caused fluctuations in the publicly displayed Indicative Opening Price. The Panel thus concluded that Kuehner violated CBOT Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Kuehner to pay a fine in the amount of $40,000, and suspended his access to all CME Group trading floors and direct and indirect access to all electronic trading and clearing platforms owned or controlled by CME Group Inc. for 10 business days. The suspension shall run from June 15, 2018, through June 28, 2018, inclusively.

EFFECTIVE DATE:

June 15, 2018