NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:          

Pei Shan Chang

CBOT RULE VIOLATION:      

Rule 539.A Prearranged, Pre-Negotiated and Noncompetitive Trades Prohibited
(in part)

No person shall prearrange or pre-negotiate any purchase or sale or noncompetitively execute any transaction.

FINDINGS:         

Pursuant to an offer of settlement in which Pei Shan Chang (“Chang”) neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on August 12, 2020, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on numerous occasions between November 23, 2018 and January 14, 2019, Chang prearranged the execution of numerous trades in the March 2019 and June 2019 E-mini Dow ($5)(“E-mini Dow”) futures market opposite other non-member traders implementing the same trading strategy. Specifically, the Panel found that Chang engaged in pre-execution communications with the other traders prior to entering matching orders, including discussing trading strategy, the timing of order placement, and the pricing of E-mini Dow futures on Globex.

The Panel concluded that Chang thereby violated CBOT Rule 539.A.

PENALTY:          

In accordance with the settlement offer, the Panel ordered Chang to pay a fine of $10,000. The Panel also suspended Chang from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group for ten (10) business days, beginning on the effective date below and continuing through and including August 27, 2020.

EFFECTIVE DATE:                

August 14, 2020