NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Ying-Jei (Karen) Tseng

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 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 Mercantile Exchange Business Conduct Committee (“Panel”) found that from January 1, 2020, to March 9, 2021, Tseng entered and canceled orders in various Foreign Exchange and Equities 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 concluded that Tseng thereby violated CME Rule 575.A.

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 CBOT 21-1422-BC, NYMEX 21-1422-BC, and COMEX 21-1422-BC ($7,500 of which is allocated to CME) 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.