NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CME 19-1171-BC

NON-MEMBER:

Todd Delay

CME RULE VIOLATION:

Rule 562. Position Limit Violations

Any positions in excess of those permitted under the rules of the Exchange shall be deemed position limit violations.

FINDINGS:

Pursuant to an offer of settlement in which Todd Delay neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on December 19, 2019, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that at the close of trading on August 5, 2019, Delay controlled a futures equivalent long position of 530 August 2019 Live Cattle futures contracts, which was 80 futures contracts (17.78%) over the spot month position limit in effect. Delay promptly liquidated the overage position, resulting in profits of $6,180. The Panel concluded that Delay thereby violated CME Rule 562.

PENALTY:

In accordance with the settlement offer, the Panel ordered Delay to pay a fine of $15,000 and disgorge profits in the amount of $6,180.

EFFECTIVE DATE:

December 23, 2019