NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

CHUNYAT CHOW

COMEX RULES:

Rule 575. Disruptive Practices Prohibited (In Part)

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.

B. No person shall enter or cause to be entered an actionable or non-actionable message or messages with intent to mislead other market participants.

Rule 432. General Offenses (in part)

It shall be an offense:

L.1. To fail to appear before the Board, Exchange staff or any investigation or hearing committee at a duly convened hearing, scheduled staff interview or in connection with any investigation.

FINDINGS:

On April 25, 2022, the Chief Regulatory Officer of CME Group’s Market Regulation Department issued charges against Chunyat Chow for violating COMEX Rules 575.A., 575.B. and 432.L.1 based on allegations that between August 13, 2020 and September 14, 2020, Chow entered orders in the December 2020 Gold Futures (“DEC20 Gold”) futures market: (1) with the intent, at the time of order entry, to cancel those orders before execution or to modify the orders to avoid execution and (2) with the intent to mislead other market participants. In addition, Chow failed to appear before Exchange staff for a scheduled interview.

On July 6, 2022, a Hearing Panel Chair of the COMEX Business Conduct Committee (“BCC”) first determined that Chow, having failed to submit a written answer to the charges issued against him, was deemed to have admitted the charges. Chow therefore waived his right to a hearing on the merits of the charges. Pursuant to COMEX Rule 408.F., a BCC Panel then found Chow guilty of committing the admitted charges and held a penalty hearing thereafter.

PENALTY:

Based on the record and the Panel’s findings and conclusions, the Panel ordered Chow to pay a fine in the amount of $75,000 and be permanently barred 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.