NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Ying-Jei (Karen) Tseng

CBOT RULE VIOLATIONS:

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.

Rule 576. Identification of Globex Terminal Operators

Each Globex terminal operator shall be identified to the Exchange, in the manner prescribed by the Exchange, and shall be subject to Exchange rules. If user IDs are required to be registered with the Exchange, it is the duty of the clearing member to ensure that registration is current and accurate at all times. Each individual must use a unique user ID to access Globex. In no event may a person enter an order or permit the entry of an order by an individual using a user ID other than the individual’s own unique user ID.

FINDINGS:

Pursuant to an offer of settlement in which Ying-Jei (Karen) Tseng neither admitted nor denied the Rule violations or factual findings upon which the penalty is based, on May 17, 2022, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that from January 1, 2020, to March 9, 2021, Tseng entered and canceled orders in Micro E-mini Dow Jones Industrial Average Index and E-mini Dow ($5) 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, Tseng entered and canceled the orders during the pre-open period to test her employer’s trading platform. The entry and cancelation of these orders caused fluctuations in the publicly displayed Indicative Opening Price. After being notified of the issue by Market Regulation, Tseng continued to enter and cancel non-bona fide test orders during the pre-open period. The Panel further found that on May 3, 2021, Tseng permitted another individual to enter orders on Globex using her unique user ID. The Panel concluded that Tseng thereby violated CBOT Rules 575.A. and 576.

PENALTY:

In accordance with the settlement offer, the Panel ordered Tseng to pay a $30,000 fine in connection with this case and companion cases CME 21-1422-BC, NYMEX 21-1422-BC, and COMEX 21-1422-BC ($7,500 of which is allocated to CBOT) 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 May 19, 2022, through June 9, 2022, inclusive.