NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 18-0896-BC

MEMBER:

Benjamin Cox

CME RULE VIOLATION:

Rule 575 DISRUPTIVE PRACTICES PROHIBITED

All orders must be entered for the purpose of executing bona fide transaction. 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 an 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 Benjamin Cox (“Cox”) neither admitted nor denied the rule violation upon which the penalty is based, on June 18, 2019, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“BCC” or “Panel”) found that between June 1, 2017, and February 22, 2018, Cox entered and cancelled orders in the March 2018 E-Mini NASDAQ 100 futures and the June 2017, September 2017, December 2017, and March 2018 E-Mini S&P 500 futures markets without the intent to trade. Specifically, the Panel found that Cox entered larger orders on one side of the order book to encourage trades opposite his smaller orders resting on the opposite side of the order book. After receiving a fill on the resting smaller orders, Cox cancelled the larger orders on the opposite side of the market. The Panel thus concluded that Cox thereby violated CME Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Cox to pay a fine of $50,000. The Panel also suspended Cox from access to any CME Group trading floor and direct and indirect access to all electronic trading and clearing platforms owned or operated by CME Group for three weeks, beginning on the effective date below and continuing through and including August 21, 2019.

EFFECTIVE DATE:

July 31, 2019