NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Laurence Stone

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 the 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 Laurence Stone neither admitted nor denied the Rule violation or factual findings upon which the penalty is based, on April 20, 2022, a Panel of the Chicago Mercantile Exchange Business Conduct Committee (“Panel”) found that from October 27, 2020, to November 26, 2020, Stone entered orders in various E-mini S&P 500 and E-mini NASDAQ 100 futures 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, Stone entered and canceled the orders during the pre-open period to discern what the orders’ impact would be on the indicative opening price (IOP), and more specifically, on the value of the Stone Family Trust account. The entry and cancelation of these orders caused fluctuations in the publicly displayed IOP. The Panel concluded that Stone thereby violated CME Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Stone to pay a $30,000 fine and to serve a 15-business day suspension 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. The suspension shall run from April 22, 2022, through May 12, 2022, inclusive.