NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:           

Paul Meech

CBOT RULE VIOLATION:                

Rule 533. Simultaneous Buy and Sell Orders for Different Beneficial Owners (in part)

On the Globex platform, opposite orders for different beneficial owners that are simultaneously placed by a party with discretion over both accounts may be entered into the Globex platform provided that one order is exposed for a minimum of 5 seconds in the case of futures orders or a minimum of 15 seconds in the case of options orders. An order allowing for price and/or time discretion, if not entered immediately upon receipt, may be knowingly entered opposite another order entered by the same firm only if this other order has been entered immediately upon receipt and has been exposed on the Globex platform for a minimum of 5 seconds for futures orders or a minimum of 15 seconds for options orders. 

FINDINGS:                    

Pursuant to an offer of settlement in which Paul Meech neither admitted nor denied the rule violation upon which the penalty is based, on August 31, 2021, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that between January 7, 2020, and May 8, 2020, Meech knowingly entered orders in various US Treasury Bond, 5-Year US Treasury Note, 10-Year US Treasury Note options on futures markets opposite resting orders placed by another trader at the same brokerage firm before the resting orders were exposed on Globex for a minimum of 15 seconds.

 The Panel concluded that Meech thereby violated CBOT Rule 533.

PENALTY:                   

In accordance with the settlement offer, the Panel ordered Meech to pay a fine in the amount of $20,000 in connection with this case and companion case CME 20-1329 ($10,000 of which is allocated to CME). The Panel also suspended Meech 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 five (5) business days, beginning on September 13, 2021, and continuing through and including September 17, 2021.

EFFECTIVE DATE:        

 September 2, 2021