NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:           

Puneet Chaudhary

CME RULE VIOLATION:                

Rule 575 Disruptive Practices Prohibited (in part)

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 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 Puneet Chaudhary neither admitted nor denied the rule violation upon which the penalty is based, on August 31, 2021, a Panel of the Chicago Mercantile Exchange (“CME”) Business Conduct Committee (“Panel”) found that between January 1, 2019, and November 12, 2019, Chaudhary entered and canceled orders in the Lumber, Feeder Cattle, and Lean Hog spread markets on the Globex electronic trading platform during the pre-open period that were not entered for the purpose of executing bona fide transactions. Rather, Chaudhary entered the orders to discern the depth of the order book. The entry and cancelation of these orders caused fluctuations in the publicly displayed Indicative Opening Price.

The Panel concluded that Chaudhary thereby violated CME Rule 575.A.

PENALTY:                   

In accordance with the settlement offer and after taking Chaudhary’s financial condition into consideration when it levied the sanction, the Panel suspended Chaudhary from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group for three months, beginning on the effective date below and continuing through and including December 2, 2021.

EFFECTIVE DATE:                         

September 2, 2021